https://www.taxtmi.com/caselaws?id=291841 A comparable may be excluded in transfer pricing analysis where abnormal profitability is driven by extraordinary factors such as restructuring, strong brand presence, and materially different turnover, because those features can distort reliability on a market basis. On that basis, the Tribunal's exclusion of Wipro Technology Services Limited as a comparable for arm's length price determination was upheld, and no substantial question of law arose. en-us Fri, 13 Apr 2018 00:00:00 +0530 Thu, 26 Nov 2020 09:18:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=291841 A comparable may be excluded in transfer pricing analysis where abnormal profitability is driven by extraordinary factors such as restructuring, strong brand presence, and materially different turnover, because those features can distort reliability on a market basis. On that basis, the Tribunal's exclusion of Wipro Technology Services Limited as a comparable for arm's length price determination was upheld, and no substantial question of law arose. Case-Laws Income Tax Fri, 13 Apr 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=291841