https://www.taxtmi.com/caselaws?id=305562 In transfer pricing benchmarking, functionally dissimilar companies with no segmental accounts and materially different asset and employee profiles were rejected as comparables. Container Corporation of India Ltd. was found incomparable because it was a large logistics business unlike the assessee's service function, and Sanco Trans Ltd. was also rejected because most of its revenue came from warehousing, equipment hire and related activities. On margin computation, fringe benefit tax had to be treated consistently for both the tested party and the comparables. The profit level indicator was therefore directed to be recomputed by applying the same operating treatment to the assessee as used for the comparables. en-us Wed, 30 Jun 2021 00:00:00 +0530 Mon, 12 Dec 2022 10:40:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=305562 In transfer pricing benchmarking, functionally dissimilar companies with no segmental accounts and materially different asset and employee profiles were rejected as comparables. Container Corporation of India Ltd. was found incomparable because it was a large logistics business unlike the assessee's service function, and Sanco Trans Ltd. was also rejected because most of its revenue came from warehousing, equipment hire and related activities. On margin computation, fringe benefit tax had to be treated consistently for both the tested party and the comparables. The profit level indicator was therefore directed to be recomputed by applying the same operating treatment to the assessee as used for the comparables. Case-Laws Income Tax Wed, 30 Jun 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=305562