https://www.taxtmi.com/caselaws?id=334187 ITAT DELHI - AT held that transfer pricing provisions do not apply to transactions between the Indian head office and its Canadian branch because branch income and balance-sheet items were merged with the head office; the impugned order was set aside pro tanto. The TPO was upheld in applying a size-based comparable filter; exclusion for companies with export revenue under 25% was modified to a 30% threshold by agreement. Related-party transaction filtering must treat sales and purchases separately. Companies with persistent losses (not merely diminishing revenues) are excluded. Companies with high onsite revenue may be included subject to verification of branch onsite/offsite break-up. Claim for idle-capacity adjustment was rejected. en-us Wed, 21 Sep 2016 00:00:00 +0530 Fri, 07 Nov 2025 18:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=334187 ITAT DELHI - AT held that transfer pricing provisions do not apply to transactions between the Indian head office and its Canadian branch because branch income and balance-sheet items were merged with the head office; the impugned order was set aside pro tanto. The TPO was upheld in applying a size-based comparable filter; exclusion for companies with export revenue under 25% was modified to a 30% threshold by agreement. Related-party transaction filtering must treat sales and purchases separately. Companies with persistent losses (not merely diminishing revenues) are excluded. Companies with high onsite revenue may be included subject to verification of branch onsite/offsite break-up. Claim for idle-capacity adjustment was rejected. Case-Laws Income Tax Wed, 21 Sep 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=334187