https://www.taxtmi.com/caselaws?id=178847 The Tribunal allowed the appeal of a 100% Shell-owned company regarding the computation of arm's length price for international transactions. Disputes arose over the inclusion and exclusion of comparables in the Transfer Pricing analysis. The Tribunal supported the exclusion of certain government-owned companies and those with high related party transactions. After excluding unsuitable comparables, the remaining companies showed an average margin of 8.68%, leading the Tribunal to conclude that the transactions were at arm's length. As a result, the Tribunal directed the Assessing Officer to delete the Transfer Pricing Adjustments, ruling in favor of the assessee. en-us Wed, 10 Dec 2014 00:00:00 +0530 Mon, 15 Feb 2016 10:23:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178847 The Tribunal allowed the appeal of a 100% Shell-owned company regarding the computation of arm's length price for international transactions. Disputes arose over the inclusion and exclusion of comparables in the Transfer Pricing analysis. The Tribunal supported the exclusion of certain government-owned companies and those with high related party transactions. After excluding unsuitable comparables, the remaining companies showed an average margin of 8.68%, leading the Tribunal to conclude that the transactions were at arm's length. As a result, the Tribunal directed the Assessing Officer to delete the Transfer Pricing Adjustments, ruling in favor of the assessee. Case-Laws Income Tax Wed, 10 Dec 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=178847