https://www.taxtmi.com/caselaws?id=193455 The Tribunal ordered the exclusion of Apitco Limited, Global Procurement Consultants Limited, and TSR Darashaw Limited from the final set of comparables for Transfer Pricing purposes due to significant functional disparities with the assessee. Emphasizing the importance of functional comparability, the Tribunal referenced a previous judgment and clarified that the Department Representative could not challenge the AO's decision on company inclusions. The matter was remanded to the AO/TPO for recalculating the Arm's Length Price of the international transaction, granting the assessee a hearing opportunity, with the appeal allowed for statistical purposes. en-us Fri, 20 Nov 2015 00:00:00 +0530 Mon, 31 Jul 2017 08:10:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=193455 The Tribunal ordered the exclusion of Apitco Limited, Global Procurement Consultants Limited, and TSR Darashaw Limited from the final set of comparables for Transfer Pricing purposes due to significant functional disparities with the assessee. Emphasizing the importance of functional comparability, the Tribunal referenced a previous judgment and clarified that the Department Representative could not challenge the AO's decision on company inclusions. The matter was remanded to the AO/TPO for recalculating the Arm's Length Price of the international transaction, granting the assessee a hearing opportunity, with the appeal allowed for statistical purposes. Case-Laws Income Tax Fri, 20 Nov 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=193455