https://www.taxtmi.com/caselaws?id=395040 The Tribunal directed that companies with related party transactions (RPT) up to 15% should be included in the set of comparables, emphasizing practicality over a 0% filter. It established that high profits alone cannot justify exclusion unless due to extraordinary circumstances. The Tribunal upheld the exclusion of certain comparables by the CIT(A) based on functional dissimilarity and directed a reevaluation of the Arm's Length Price (ALP). Regarding deduction under section 10A for reversed management charges, the Tribunal remanded the issue for verification, emphasizing the need to consider past treatment of provisions. The Tribunal's decision promotes a balanced and legally sound approach to transfer pricing and deductions. en-us Fri, 28 Feb 2020 00:00:00 +0530 Mon, 04 May 2020 12:42:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=395040 The Tribunal directed that companies with related party transactions (RPT) up to 15% should be included in the set of comparables, emphasizing practicality over a 0% filter. It established that high profits alone cannot justify exclusion unless due to extraordinary circumstances. The Tribunal upheld the exclusion of certain comparables by the CIT(A) based on functional dissimilarity and directed a reevaluation of the Arm's Length Price (ALP). Regarding deduction under section 10A for reversed management charges, the Tribunal remanded the issue for verification, emphasizing the need to consider past treatment of provisions. The Tribunal's decision promotes a balanced and legally sound approach to transfer pricing and deductions. Case-Laws Income Tax Fri, 28 Feb 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=395040