https://www.taxtmi.com/caselaws?id=311395 ITAT Bangalore held that TPO's turnover filter of Rs.1 crore to Rs.200 crores for comparable selection was inappropriate, directing application of 10 times turnover filter instead. Ten companies were excluded for excessive turnover and five for functional dissimilarity, leaving only two valid comparables. TPO directed to recompute ALP accordingly. For Section 10A computation, expenses excluded from export turnover numerator must also be excluded from total turnover denominator. Employee stock compensation deduction claim was remanded to AO for verification and proper apportionment between 10A and non-10A units. en-us Mon, 31 Oct 2016 00:00:00 +0530 Sat, 23 Dec 2023 09:44:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311395 ITAT Bangalore held that TPO's turnover filter of Rs.1 crore to Rs.200 crores for comparable selection was inappropriate, directing application of 10 times turnover filter instead. Ten companies were excluded for excessive turnover and five for functional dissimilarity, leaving only two valid comparables. TPO directed to recompute ALP accordingly. For Section 10A computation, expenses excluded from export turnover numerator must also be excluded from total turnover denominator. Employee stock compensation deduction claim was remanded to AO for verification and proper apportionment between 10A and non-10A units. Case-Laws Income Tax Mon, 31 Oct 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311395