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ITAT directed exclusion from the comparability set of several large group-affiliated IT service providers on the ground that their substantial turnover, brand-derived intangibles and resultant economies of scale render them non-comparable with the tested party; the Tribunal upheld the inclusion of two specified comparables as functionally comparable, rejecting the assessee's contention that profit volatility or lack of segmental disclosure justified exclusion absent demonstration of extraordinary events; the Tribunal dismissed the assessee's attempt to import companies not appearing in the TPO's search matrix as impermissible cherry-picking; and remitted the issue of working-capital adjustment to the TPO for fresh consideration and computation after hearing.
ITAT directed exclusion from the comparability set of several large group-affiliated IT service providers on the ground that their substantial turnover, brand-derived intangibles and resultant economies of scale render them non-comparable with the tested party; the Tribunal upheld the inclusion of two specified comparables as functionally comparable, rejecting the assessee's contention that profit volatility or lack of segmental disclosure justified exclusion absent demonstration of extraordinary events; the Tribunal dismissed the assessee's attempt to import companies not appearing in the TPO's search matrix as impermissible cherry-picking; and remitted the issue of working-capital adjustment to the TPO for fresh consideration and computation after hearing.
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