Tribunal Rules on Transfer Pricing: Exclude High Turnover Companies for Comparability, Remands Working Capital Adjustment.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....The Tribunal held that the Transfer Pricing Officer (TPO)/Assessing Officer (AO) should exclude companies having turnover exceeding Rs. 200 crores from the comparability analysis while calculating the arm's length price (ALP) of the assessee's international transactions with its associated enterprise, after necessary verification. The companies ICRA Techno Analytics Ltd and Kals Information Systems Ltd. were found functionally different from the assessee engaged in software development services and hence cannot be included as comparables. However, Quintegra Solution Limited, being functionally similar and having similar turnover, cannot be excluded merely for showing losses due to extraordinary deductions. The AO/TPO was directed to include.........