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ITAT ruled that multiple proposed comparables were inappropriate for transfer pricing analysis due to fundamental differences in business models, product types, and operational characteristics. The tribunal systematically rejected comparables from various retail, textile, and fashion companies, emphasizing that the appellant's felt packaging material business significantly differs from the proposed comparables' core operations. The key considerations included divergent revenue sources, product nature, market dynamics, and functional profiles. The tribunal concluded that none of the suggested companies could serve as valid comparables for transfer pricing determination, thereby maintaining the arm's length principle in assessing international transaction pricing.
ITAT ruled that multiple proposed comparables were inappropriate for transfer pricing analysis due to fundamental differences in business models, product types, and operational characteristics. The tribunal systematically rejected comparables from various retail, textile, and fashion companies, emphasizing that the appellant's felt packaging material business significantly differs from the proposed comparables' core operations. The key considerations included divergent revenue sources, product nature, market dynamics, and functional profiles. The tribunal concluded that none of the suggested companies could serve as valid comparables for transfer pricing determination, thereby maintaining the arm's length principle in assessing international transaction pricing.
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