High Court Affirms ITAT Ruling: Importance of Selecting Comparable Entities in Transfer Pricing Adjustments.

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....TP Adjustment - comparable selection - The High Court upheld the ITAT's decision, emphasizing the principle of comparing entities with similar characteristics. It acknowledged the appellant's argument that the comparables had been in business for many years, whereas the appellant had only started operations recently. The High Court agreed that comparing entities with different operational histories was inappropriate. It noted that the appellant's expenses were similar to those of subsequent years when sales had increased, indicating business stabilization.....