Tribunal held that BEML being a Government company is not includible in the list of comparbles. Tribunal also held that since 99. 65 per cent of the manufacturing activity of JCB Ltd in functionally similar to that of the assessee. It cannot be excluded from the list of comparables. (AY. 2011-12)
ACIT v. Hyundai Construction India (P) Ltd. (2021) 213 TTJ 203 (Pune)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Comparable-BEM being a Government company-Not includible in the list of comparables-99.65 per cent of the manufacturing activity of JCB Ltd is functionally similar-Included in the comparables. [R. 10B]