The Tribunal held that the turnover filter the company could be compared, but the company did not pass the functional analysis as it was functionally dissimilar being a manufacturer of voltage panels and was liable to be excluded from the list of comparables. (AY. 2016-17)
Aggressive Digital Systems Pvt. Ltd v. ITO (2022)97 ITR 687 (Delhi) (Trib)
S. 92C : Transfer pricing-Arm’s length price-Manufacture and assembly-Comparable-Company passed turnover filter but fails to pass functional analysis-Department’s appeal to remand the matter not justified and entertained-Addition was deleted [S.92CA]