Company owning dissimilar assets be excluded from the list of final comparables for ALP by TPO - ADP Private Ltd. Vs DCIT

Last updated: 12 January 2021
Quick Summary
The Income Tax Appellate Tribunal ruled that a company owning dissimilar assets should not be included in the list of final comparables for determining the Arms' Length Price (ALP) by the Transfer Pricing Officer (TPO). This decision impacts how international transactions between associated enterprises are assessed for tax purposes.

Court :
ITAT Hyderabad

Brief :
This is assessee’s appeal for the A.Y 2014-15 against the final assessment order passed u/s 143(3) r.w.s. 92CA of the Act dated 30.10.2018.

Citation :
ITA No.2233/Hyd/2018

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