Flawed Transfer Pricing Analysis: Inclusion of Incomparable Firm Despite Lack of Data Scrutiny.

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....Transfer pricing adjustment regarding inclusion of E4e Healthcare as a comparable company. Assessee objected due to unavailability of annual report. However, objections were not adjudicated as Transfer Pricing Officer determined arm's length price adjustment as nil for the relevant year. Assessee's contention that E4e Healthcare is functionally dissimilar and cannot be included as a comparable was not considered by any authority. Orders passed by authorities were based on incorrect assumptions.....