https://www.taxtmi.com/caselaws?id=470762 Tested-party selection in transfer-pricing analysis requires identifying the less complex entity for which reliable comparable data are available. The foreign associated enterprise, which primarily procured work and had limited assets and personnel, could not be rejected as the tested party solely because it was foreign, while the assessee performed core debt-collection functions and owned the principal infrastructure and operating assets. The availability and reliability of comparable data for the foreign enterprise required examination. The arm's length price determination was remitted for fresh consideration of that tested-party selection after affording the assessee a reasonable hearing. en-us Thu, 23 Aug 2018 00:00:00 +0530 Fri, 07 Aug 2026 12:12:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470762 Tested-party selection in transfer-pricing analysis requires identifying the less complex entity for which reliable comparable data are available. The foreign associated enterprise, which primarily procured work and had limited assets and personnel, could not be rejected as the tested party solely because it was foreign, while the assessee performed core debt-collection functions and owned the principal infrastructure and operating assets. The availability and reliability of comparable data for the foreign enterprise required examination. The arm's length price determination was remitted for fresh consideration of that tested-party selection after affording the assessee a reasonable hearing. Case-Laws Income Tax Thu, 23 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470762