https://www.taxtmi.com/caselaws?id=758861 The ITAT Hyderabad ruled on transfer pricing comparable selection criteria, directing the AO/TPO to apply a turnover filter of ten times on both sides of the assessee's turnover for fresh comparable search, following Karnataka HC precedent. The tribunal excluded three entities (Vitae International Accounting Services, Domex E Data, and MPS Ltd.) from comparables as their functions fell under Rule 10TA(g) clauses (iv)-(vii), making them non-comparable to the assessee. However, Motiff India Infotech was retained as a comparable despite high advertising expenses, as the DRP found no evidence that such expenses impacted revenues. The appeal was allowed for statistical purposes with directions for fresh ALP determination. en-us Fri, 28 Jun 2024 00:00:00 +0530 Thu, 19 Sep 2024 11:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758861 The ITAT Hyderabad ruled on transfer pricing comparable selection criteria, directing the AO/TPO to apply a turnover filter of ten times on both sides of the assessee's turnover for fresh comparable search, following Karnataka HC precedent. The tribunal excluded three entities (Vitae International Accounting Services, Domex E Data, and MPS Ltd.) from comparables as their functions fell under Rule 10TA(g) clauses (iv)-(vii), making them non-comparable to the assessee. However, Motiff India Infotech was retained as a comparable despite high advertising expenses, as the DRP found no evidence that such expenses impacted revenues. The appeal was allowed for statistical purposes with directions for fresh ALP determination. Case-Laws Income Tax Fri, 28 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758861