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ITAT adjudicated transfer pricing dispute regarding comparable company selection. The tribunal determined the Arm's Length Price (ALP) computation by the Transfer Pricing Officer (TPO) was fair and reasonable, with a critical modification. The tribunal directed exclusion of one specific comparable company due to significantly divergent operating margin of 38% from toll operations. Consequently, the Assessing Officer (AO) was instructed to recalculate the transfer pricing adjustment using the average Profit Level Indicator (PLI) derived from the remaining 11 comparable companies. The ruling effectively refined the methodology for establishing an accurate arm's length benchmark while maintaining the substantive framework of the original transfer pricing assessment.
ITAT adjudicated transfer pricing dispute regarding comparable company selection. The tribunal determined the Arm's Length Price (ALP) computation by the Transfer Pricing Officer (TPO) was fair and reasonable, with a critical modification. The tribunal directed exclusion of one specific comparable company due to significantly divergent operating margin of 38% from toll operations. Consequently, the Assessing Officer (AO) was instructed to recalculate the transfer pricing adjustment using the average Profit Level Indicator (PLI) derived from the remaining 11 comparable companies. The ruling effectively refined the methodology for establishing an accurate arm's length benchmark while maintaining the substantive framework of the original transfer pricing assessment.
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