https://www.taxtmi.com/highlights?id=74989 TP Adjustment - comparable selection - The ITAT that the turnover filter cannot be applied as a tool for cherry picking the comparables at the later stage after completion of the search process with the object of excluding comparables which was otherwise found to be functionally comparables after the Functions Assets Risks (FAR) Analysis. - The application of the second lower turnover filter by the TPO without rejecting the first turnover filter adopted by the Appellant resulted exclusion of two companies which were otherwise functionally comparable and thus, resulted in cherry picking. - TPO directed to recompute the arm's length price (ALP) accordingly. en-us Sat, 17 Feb 2024 06:50:11 +0530 Sat, 17 Feb 2024 06:50:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=74989 TP Adjustment - comparable selection - The ITAT that the turnover filter cannot be applied as a tool for cherry picking the comparables at the later stage after completion of the search process with the object of excluding comparables which was otherwise found to be functionally comparables after the Functions Assets Risks (FAR) Analysis. - The application of the second lower turnover filter by the TPO without rejecting the first turnover filter adopted by the Appellant resulted exclusion of two companies which were otherwise functionally comparable and thus, resulted in cherry picking. - TPO directed to recompute the arm's length price (ALP) accordingly. Highlights Income Tax Sat, 17 Feb 2024 06:50:11 +0530 https://www.taxtmi.com/highlights?id=74989