https://www.taxtmi.com/caselaws?id=192381 The Tribunal upheld the exclusion of companies with related party transactions and profits exceeding 50% of cost as comparables, emphasizing the need for accurate benchmarking free from related party influences and functional differences. Companies like Infosys Technologies Ltd. were excluded based on size, turnover, and brand differences. Foreign exchange gains/losses were considered part of operating costs. A standard 5% deduction from the Arm's Length Price was allowed. The Tribunal supported fresh economic analysis over the assessee's, considering data availability and the application of various filters for comparables. Adjustments for risk profile differences were not mandated. The judgment favored the assessee, emphasizing the importance of reliable data in transfer pricing assessments for fair tax administration. en-us Wed, 23 Nov 2016 00:00:00 +0530 Mon, 29 May 2017 08:22:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=192381 The Tribunal upheld the exclusion of companies with related party transactions and profits exceeding 50% of cost as comparables, emphasizing the need for accurate benchmarking free from related party influences and functional differences. Companies like Infosys Technologies Ltd. were excluded based on size, turnover, and brand differences. Foreign exchange gains/losses were considered part of operating costs. A standard 5% deduction from the Arm's Length Price was allowed. The Tribunal supported fresh economic analysis over the assessee's, considering data availability and the application of various filters for comparables. Adjustments for risk profile differences were not mandated. The judgment favored the assessee, emphasizing the importance of reliable data in transfer pricing assessments for fair tax administration. Case-Laws Income Tax Wed, 23 Nov 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=192381