https://www.taxtmi.com/caselaws?id=762810 The Delhi HC upheld ITAT's decision to exclude four companies as comparables for transfer pricing benchmarking under TNMM method. The court held that despite TNMM being broadly tolerant to functional dissimilarity, essential similarity in broad functional profiles remains necessary. The excluded entities - Kitco Ltd. (infrastructure, tourism, aviation, IT services), TCE Consulting Engineers Ltd. (high-end technical services), Project and Development India Ltd., and Mahindra Consulting Engineers Ltd. - were found functionally incomparable to the assessee's engineering and design services through FAR analysis. The ITAT's exclusion findings aligned with ALP provisions under Section 92C. en-us Mon, 25 Nov 2024 00:00:00 +0530 Sat, 07 Dec 2024 08:14:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762810 The Delhi HC upheld ITAT's decision to exclude four companies as comparables for transfer pricing benchmarking under TNMM method. The court held that despite TNMM being broadly tolerant to functional dissimilarity, essential similarity in broad functional profiles remains necessary. The excluded entities - Kitco Ltd. (infrastructure, tourism, aviation, IT services), TCE Consulting Engineers Ltd. (high-end technical services), Project and Development India Ltd., and Mahindra Consulting Engineers Ltd. - were found functionally incomparable to the assessee's engineering and design services through FAR analysis. The ITAT's exclusion findings aligned with ALP provisions under Section 92C. Case-Laws Income Tax Mon, 25 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762810