https://www.taxtmi.com/caselaws?id=760548 ITAT Delhi directed exclusion of multiple companies from transfer pricing comparables for an auto components manufacturer. Brakes India Pvt. Ltd., Clutch Auto Ltd., and ANG Industries Ltd. were excluded due to functional dissimilarity, high export sales, and different geographical markets respectively. Faiveley Transport and Rane Brake Lining Ltd. were excluded for high AMP expense ratios exceeding 2% filter. However, XLO India Ltd. was retained despite negative net worth as profits improved over three years. Foreign exchange gains must be included in operating income calculations. TPO directed to reconsider depreciation adjustments for profit level indicators following precedent decisions. en-us Wed, 16 Oct 2024 00:00:00 +0530 Tue, 22 Oct 2024 09:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760548 ITAT Delhi directed exclusion of multiple companies from transfer pricing comparables for an auto components manufacturer. Brakes India Pvt. Ltd., Clutch Auto Ltd., and ANG Industries Ltd. were excluded due to functional dissimilarity, high export sales, and different geographical markets respectively. Faiveley Transport and Rane Brake Lining Ltd. were excluded for high AMP expense ratios exceeding 2% filter. However, XLO India Ltd. was retained despite negative net worth as profits improved over three years. Foreign exchange gains must be included in operating income calculations. TPO directed to reconsider depreciation adjustments for profit level indicators following precedent decisions. Case-Laws Income Tax Wed, 16 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760548