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    <title>2016 (5) TMI 137 - BOMBAY HIGH COURT</title>
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    <description>HC upheld the tribunal&#039;s finding that the profits of the five alleged comparable companies were abnormal and not benchmarkable against the taxpayer. The Revenue failed to rebut the data and did not show how functions, assets and risks of those companies were sufficiently comparable to the assessee. The court agreed that the companies were larger, operated in different service areas, and that turnover and economically relevant characteristics render them unsuitable comparators, so transfer pricing adjustment was not warranted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=327156</link>
      <description>HC upheld the tribunal&#039;s finding that the profits of the five alleged comparable companies were abnormal and not benchmarkable against the taxpayer. The Revenue failed to rebut the data and did not show how functions, assets and risks of those companies were sufficiently comparable to the assessee. The court agreed that the companies were larger, operated in different service areas, and that turnover and economically relevant characteristics render them unsuitable comparators, so transfer pricing adjustment was not warranted.</description>
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      <pubDate>Wed, 16 Sep 2015 00:00:00 +0530</pubDate>
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