https://www.taxtmi.com/caselaws?id=307303 In transfer pricing comparability analysis, a company must satisfy the material factors under Rule 10B(2) and remain sufficiently similar to the tested entity for reliable arm's length benchmarking. The Delhi HC noted that wide deviations and material dissimilarities justify exclusion. On the facts, Excel Infoways Ltd. failed the applicable service revenue export/ITES filter and also did not meet the diminishing revenue filter reflected in its financial data, so it could not be retained as a comparable. The Tribunal's exclusion of the company was therefore upheld. en-us Fri, 29 Jul 2022 00:00:00 +0530 Tue, 04 Apr 2023 20:58:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307303 In transfer pricing comparability analysis, a company must satisfy the material factors under Rule 10B(2) and remain sufficiently similar to the tested entity for reliable arm's length benchmarking. The Delhi HC noted that wide deviations and material dissimilarities justify exclusion. On the facts, Excel Infoways Ltd. failed the applicable service revenue export/ITES filter and also did not meet the diminishing revenue filter reflected in its financial data, so it could not be retained as a comparable. The Tribunal's exclusion of the company was therefore upheld. Case-Laws Income Tax Fri, 29 Jul 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307303