https://www.taxtmi.com/caselaws?id=277047 Application of a turnover filter in comparable selection for transfer pricing ALP determination was considered; the ITAT affirmed the CIT(A)'s exclusion of high-turnover and functionally dissimilar companies following the Genisys ratio, reasoning that a captive service provider assumes less than normal business and entrepreneurial risks so comparables bearing significant risks must be deselected, and that an amalgamating entity showing abnormal profit was rightly excluded. The TPO/AO is directed to compute ALP per those directions and, if the assessee qualifies, grant the tolerance limit benefit under the second proviso to Sec.92CA(2). en-us Fri, 06 Jul 2018 00:00:00 +0530 Thu, 15 Jan 2026 15:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=277047 Application of a turnover filter in comparable selection for transfer pricing ALP determination was considered; the ITAT affirmed the CIT(A)'s exclusion of high-turnover and functionally dissimilar companies following the Genisys ratio, reasoning that a captive service provider assumes less than normal business and entrepreneurial risks so comparables bearing significant risks must be deselected, and that an amalgamating entity showing abnormal profit was rightly excluded. The TPO/AO is directed to compute ALP per those directions and, if the assessee qualifies, grant the tolerance limit benefit under the second proviso to Sec.92CA(2). Case-Laws Income Tax Fri, 06 Jul 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277047