Transfer Pricing Adjustment: M/s Asco (India) Ltd. Not Comparable Due to Functional Differences in Manufacturing Processes.

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....TP adjustment - Comparability - Functional dissimilarity - there is wide difference in the functions of a manufacturer and assembler. It is further stated that the assessee’s hydraulic products used fluids for movement of parts of a system. M/s Asco (India) Ltd. manufacturers Nuematic products which use Air as a medium for movement of parts of a system. - Asco (India) Ltd. could not be functionally comparable with the assessee and hence it cannot be considered as comparable company in the hands of the assessee. - AT....