https://www.taxtmi.com/caselaws?id=196521 The Tribunal directed the exclusion of APTICO Ltd. and TSR Darashaw from the list of comparables in a transfer pricing dispute, affirming the appellant's claims based on the distinct nature of services provided by these companies. Additionally, the Tribunal acknowledged the inclusion of certain functionally dissimilar companies did not impact the arm's length price for the year under consideration but reserved the appellant's right to contest their inclusion in future years. The issue of adjustment for differences in working capital was restored to the Transfer Pricing Officer for a decision on merit, allowing the appellant an opportunity to demonstrate differences in working capital levels vis-`a-vis comparables. en-us Wed, 10 Aug 2016 00:00:00 +0530 Mon, 04 Dec 2017 21:08:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=196521 The Tribunal directed the exclusion of APTICO Ltd. and TSR Darashaw from the list of comparables in a transfer pricing dispute, affirming the appellant's claims based on the distinct nature of services provided by these companies. Additionally, the Tribunal acknowledged the inclusion of certain functionally dissimilar companies did not impact the arm's length price for the year under consideration but reserved the appellant's right to contest their inclusion in future years. The issue of adjustment for differences in working capital was restored to the Transfer Pricing Officer for a decision on merit, allowing the appellant an opportunity to demonstrate differences in working capital levels vis-`a-vis comparables. Case-Laws Income Tax Wed, 10 Aug 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=196521