https://www.taxtmi.com/caselaws?id=758105 ITAT Hyderabad ruled on transfer pricing comparable selection in a trading activity case. The tribunal excluded five companies (ACL, Hughes, HCL, Uniinfo, Seven-3) from comparables due to functional dissimilarity, as their revenue primarily came from services while the assessee engaged in trading. S.K. Communications was also excluded for similar reasons. However, Arya and Cineom were retained as comparables since their trading revenue constituted 97.45% and 82.80% respectively of total operations. The tribunal directed the AO to verify Globe's comparability after the assessee provided its annual report, allowing this ground for statistical purposes. en-us Thu, 29 Aug 2024 00:00:00 +0530 Sat, 07 Sep 2024 08:18:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758105 ITAT Hyderabad ruled on transfer pricing comparable selection in a trading activity case. The tribunal excluded five companies (ACL, Hughes, HCL, Uniinfo, Seven-3) from comparables due to functional dissimilarity, as their revenue primarily came from services while the assessee engaged in trading. S.K. Communications was also excluded for similar reasons. However, Arya and Cineom were retained as comparables since their trading revenue constituted 97.45% and 82.80% respectively of total operations. The tribunal directed the AO to verify Globe's comparability after the assessee provided its annual report, allowing this ground for statistical purposes. Case-Laws Income Tax Thu, 29 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758105