Determining arm's length price: Excluding functionally incomparable companies, including similar ones.

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....The Income Tax Appellate Tribunal (ITAT) held that in determining the arm's length price for transfer pricing adjustments, three companies (MOIAPL, LCAPL, and MOEPAPL) should be excluded from the comparable list as they were functionally not comparable to the assessee, following the binding order of the Coordinate Bench of ITAT, Mumbai. However, the ITAT directed the Transfer Pricing Officer/Assessing Officer to include three other companies (ICRA, Cyber, and ITIL) in the list of comparables and calculate the arm's length price accordingly, as they were functionally similar to the assessee, in line with the orders of the coordinate benches of ITAT-Mumbai.....