https://www.taxtmi.com/highlights?id=66938 TP adjustment - Comparability - Functional dissimilarity - there is wide difference in the functions of a manufacturer and assembler. It is further stated that the assessee’s hydraulic products used fluids for movement of parts of a system. M/s Asco (India) Ltd. manufacturers Nuematic products which use Air as a medium for movement of parts of a system. - Asco (India) Ltd. could not be functionally comparable with the assessee and hence it cannot be considered as comparable company in the hands of the assessee. - AT en-us Tue, 06 Dec 2022 09:37:51 +0530 Tue, 06 Dec 2022 09:37:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=66938 TP adjustment - Comparability - Functional dissimilarity - there is wide difference in the functions of a manufacturer and assembler. It is further stated that the assessee’s hydraulic products used fluids for movement of parts of a system. M/s Asco (India) Ltd. manufacturers Nuematic products which use Air as a medium for movement of parts of a system. - Asco (India) Ltd. could not be functionally comparable with the assessee and hence it cannot be considered as comparable company in the hands of the assessee. - AT Highlights Income Tax Tue, 06 Dec 2022 09:37:51 +0530 https://www.taxtmi.com/highlights?id=66938