https://www.taxtmi.com/caselaws?id=449675 ITAT Mumbai ruled in favor of the appellant regarding transfer pricing comparable selection. The TPO improperly applied additional turnover filters (1/10th to 10 times) after accepting appellant's initial INR 1 crore filter, excluding two functionally comparable companies - APITCO Ltd and IDMA Laboratories. The tribunal held this constituted cherry-picking of comparables, as the excluded companies were functionally comparable after FAR analysis. CIT(A) incorrectly upheld the additional filters. ITAT directed TPO/AO to recompute arm's length price including both excluded comparables in the final set. en-us Fri, 22 Dec 2023 00:00:00 +0530 Mon, 08 Jun 2026 14:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449675 ITAT Mumbai ruled in favor of the appellant regarding transfer pricing comparable selection. The TPO improperly applied additional turnover filters (1/10th to 10 times) after accepting appellant's initial INR 1 crore filter, excluding two functionally comparable companies - APITCO Ltd and IDMA Laboratories. The tribunal held this constituted cherry-picking of comparables, as the excluded companies were functionally comparable after FAR analysis. CIT(A) incorrectly upheld the additional filters. ITAT directed TPO/AO to recompute arm's length price including both excluded comparables in the final set. Case-Laws Income Tax Fri, 22 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449675