https://www.taxtmi.com/caselaws?id=438449 ITAT, Bangalore partly allowed the appeal. It held that entities with turnover exceeding Rs.200 crore should be excluded as comparables when the assessee's turnover is low, directed the TPO to apply the turnover filter and to allow the claimed working-capital adjustment, and remitted the transfer-pricing issue to the TPO for de novo consideration with an opportunity of hearing. The Tribunal also held that transactions with local vendors not influenced by the AE are not deemed international transactions and directed the TPO to consider only AE transactions for ALP determination. en-us Mon, 27 Feb 2023 00:00:00 +0530 Fri, 29 Aug 2025 14:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=438449 ITAT, Bangalore partly allowed the appeal. It held that entities with turnover exceeding Rs.200 crore should be excluded as comparables when the assessee's turnover is low, directed the TPO to apply the turnover filter and to allow the claimed working-capital adjustment, and remitted the transfer-pricing issue to the TPO for de novo consideration with an opportunity of hearing. The Tribunal also held that transactions with local vendors not influenced by the AE are not deemed international transactions and directed the TPO to consider only AE transactions for ALP determination. Case-Laws Income Tax Mon, 27 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=438449