https://www.taxtmi.com/caselaws?id=283557 For transfer pricing benchmarking, materially high-turnover companies are not reliable comparables for a small-sized enterprise, and a turnover-based size filter may justify their exclusion. Applying that principle, companies with several-hundred-crore turnover were excluded where the assessee's turnover was about Rs. 20 crore. Two other comparables were sent back for fresh examination because objections on functional dissimilarity, related-party transactions and margin computation remained to be reconsidered. The transfer pricing exercise was therefore partly adjusted in the assessee's favour through exclusion of unsuitable comparables and remand of disputed comparables for reassessment. en-us Fri, 28 Jun 2019 00:00:00 +0530 Sat, 28 Sep 2019 14:24:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=283557 For transfer pricing benchmarking, materially high-turnover companies are not reliable comparables for a small-sized enterprise, and a turnover-based size filter may justify their exclusion. Applying that principle, companies with several-hundred-crore turnover were excluded where the assessee's turnover was about Rs. 20 crore. Two other comparables were sent back for fresh examination because objections on functional dissimilarity, related-party transactions and margin computation remained to be reconsidered. The transfer pricing exercise was therefore partly adjusted in the assessee's favour through exclusion of unsuitable comparables and remand of disputed comparables for reassessment. Case-Laws Income Tax Fri, 28 Jun 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=283557