https://www.taxtmi.com/caselaws?id=238292 ITAT (HYD) held that the assessee's selection of comparables under CPM was partly acceptable: companies with turnover > Rs.100 crore were excluded; employee-cost-to-sales and onsite-income filters could not be applied due to unavailable data; loss-making and super-profit companies were excluded. The tribunal denied the assessee's claim to the ±5% proviso under s.92C(2) in view of s.92C(2A)'s retrospective effect. It allowed a 1% risk adjustment to the adjusted average PLI. On method, the tribunal accepted the Revenue's application of TNMM as the most appropriate method and decided that point for the Revenue. en-us Tue, 15 Jan 2013 00:00:00 +0530 Wed, 27 Aug 2025 14:37:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=238292 ITAT (HYD) held that the assessee's selection of comparables under CPM was partly acceptable: companies with turnover > Rs.100 crore were excluded; employee-cost-to-sales and onsite-income filters could not be applied due to unavailable data; loss-making and super-profit companies were excluded. The tribunal denied the assessee's claim to the ±5% proviso under s.92C(2) in view of s.92C(2A)'s retrospective effect. It allowed a 1% risk adjustment to the adjusted average PLI. On method, the tribunal accepted the Revenue's application of TNMM as the most appropriate method and decided that point for the Revenue. Case-Laws Income Tax Tue, 15 Jan 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=238292