https://www.taxtmi.com/caselaws?id=470762 Tested-party selection in transfer pricing requires identifying the less complex entity for which reliable comparable data is available. The notes state that the assessee performed core debt-collection operations and owned the principal infrastructure and operating assets, while the foreign associated enterprise mainly procured work with relatively limited assets and personnel. Selection of the foreign enterprise could not be rejected solely because it was foreign; the availability and reliability of comparable data for that entity required examination. The arm's length price determination was remitted for fresh adjudication after examining adoption of the foreign associated enterprise as the tested party and allowing a reasonable hearing opportunity. 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 requires identifying the less complex entity for which reliable comparable data is available. The notes state that the assessee performed core debt-collection operations and owned the principal infrastructure and operating assets, while the foreign associated enterprise mainly procured work with relatively limited assets and personnel. Selection of the foreign enterprise could not be rejected solely because it was foreign; the availability and reliability of comparable data for that entity required examination. The arm's length price determination was remitted for fresh adjudication after examining adoption of the foreign associated enterprise as the tested party and allowing a reasonable hearing opportunity. Case-Laws Income Tax Thu, 23 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470762