https://www.taxtmi.com/caselaws?id=776636 ITAT Delhi upheld the CIT(A)'s exclusion of several companies as comparables in transfer pricing adjustments due to functional dissimilarities, involvement in multiple business activities, or extraordinary events like amalgamations that could not be reliably adjusted. Entities engaged in KPO services, product development with unique intellectual property, or significantly larger scale and brand value were excluded. The tribunal accepted inclusion of Vishal Information Technologies Ltd. as a suitable comparable due to similar ITeS activities and justified profit margins. Overall, the ITAT affirmed selective exclusion and inclusion of comparables based on functional and financial comparability, declining to interfere with the CIT(A)'s findings. en-us Fri, 09 May 2025 00:00:00 +0530 Thu, 14 Aug 2025 08:26:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776636 ITAT Delhi upheld the CIT(A)'s exclusion of several companies as comparables in transfer pricing adjustments due to functional dissimilarities, involvement in multiple business activities, or extraordinary events like amalgamations that could not be reliably adjusted. Entities engaged in KPO services, product development with unique intellectual property, or significantly larger scale and brand value were excluded. The tribunal accepted inclusion of Vishal Information Technologies Ltd. as a suitable comparable due to similar ITeS activities and justified profit margins. Overall, the ITAT affirmed selective exclusion and inclusion of comparables based on functional and financial comparability, declining to interfere with the CIT(A)'s findings. Case-Laws Income Tax Fri, 09 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776636