https://www.taxtmi.com/caselaws?id=208965 Transfer pricing comparables for determining ALP were in dispute, specifically the inclusion of three software companies alleged to be supernormal profit earners and, in one case, having significant related party transactions. The Tribunal held that the TPO failed to deal with objections with reasons, ignored material showing related party transactions, and relied on superficial grounds (listed status/audit) despite undisputed supernormal margins; accordingly, all three companies were directed to be excluded from the comparable set. Upon recomputation using TPO data after exclusion, the arithmetic mean OP/OC became 17.15%, falling within the ±5% tolerance under s.92C(2), resulting in no transfer pricing adjustment and relief to the assessee. The DRP's cursory order was held contrary to s.144C. en-us Fri, 21 Jan 2011 00:00:00 +0530 Mon, 22 Dec 2025 12:35:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=208965 Transfer pricing comparables for determining ALP were in dispute, specifically the inclusion of three software companies alleged to be supernormal profit earners and, in one case, having significant related party transactions. The Tribunal held that the TPO failed to deal with objections with reasons, ignored material showing related party transactions, and relied on superficial grounds (listed status/audit) despite undisputed supernormal margins; accordingly, all three companies were directed to be excluded from the comparable set. Upon recomputation using TPO data after exclusion, the arithmetic mean OP/OC became 17.15%, falling within the ±5% tolerance under s.92C(2), resulting in no transfer pricing adjustment and relief to the assessee. The DRP's cursory order was held contrary to s.144C. Case-Laws Income Tax Fri, 21 Jan 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=208965