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The ITAT held that three proposed comparables (Comparable A,...
Three comparables excluded as functionally dissimilar; assessee's 15.25% margin arm's-length under Section 92C; Section 10AA deduction reexamined under Section 154
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The ITAT held that three proposed comparables (Comparable A, Comparable B, Comparable C) are functionally dissimilar to the assessee and must be excluded from the comparable set. Comparable A was engaged in product development, owned significant intangibles and derived substantial non-service revenue; Comparable B was principally a packaged-software trader and geospatial services provider; Comparable C was predominantly a distributor with a materially different cost and employee profile. On exclusion of these entities, the assessee's operating margin of 15.25% falls within the permissible arm's-length range under section 92C, and no transfer-pricing adjustment survives. The AO was directed to re-examine and rectify the denied deduction claim under section 10AA pursuant to the assessee's section 154 application.
The ITAT held that three proposed comparables (Comparable A, Comparable B, Comparable C) are functionally dissimilar to the assessee and must be excluded from the comparable set. Comparable A was engaged in product development, owned significant intangibles and derived substantial non-service revenue; Comparable B was principally a packaged-software trader and geospatial services provider; Comparable C was predominantly a distributor with a materially different cost and employee profile. On exclusion of these entities, the assessee's operating margin of 15.25% falls within the permissible arm's-length range under section 92C, and no transfer-pricing adjustment survives. The AO was directed to re-examine and rectify the denied deduction claim under section 10AA pursuant to the assessee's section 154 application.
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