https://www.taxtmi.com/caselaws?id=325974 The Tribunal found the exclusion of M/s. Gillanders Arbuthnot & Co. Ltd. as a comparable erroneous, as it engaged in turnkey projects, meeting comparability criteria. The exclusion of M/s. Engineers India Ltd. was upheld due to its incomparability based on revenue sources. A royalty payment was allowed as Arm's Length Price, prompting a significant adjustment. Some issues were dismissed for lack of legal questions, while others were admitted for further review, highlighting the significance of precise comparability analysis and ALP determination in transfer pricing assessments. en-us Mon, 28 Mar 2016 00:00:00 +0530 Wed, 10 Aug 2016 18:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=325974 The Tribunal found the exclusion of M/s. Gillanders Arbuthnot & Co. Ltd. as a comparable erroneous, as it engaged in turnkey projects, meeting comparability criteria. The exclusion of M/s. Engineers India Ltd. was upheld due to its incomparability based on revenue sources. A royalty payment was allowed as Arm's Length Price, prompting a significant adjustment. Some issues were dismissed for lack of legal questions, while others were admitted for further review, highlighting the significance of precise comparability analysis and ALP determination in transfer pricing assessments. Case-Laws Income Tax Mon, 28 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=325974