Aithent Technologies (P.) Ltd. v. ITO (2020) 182 ITD 169 (Delhi) (Trib.)

S. 92C : Transfer pricing-Arm’s length price-Comparable-Matter remanded to the TPO-Turnover cap-Goodwill-Loss making companies-Size and Economies of Sale/High Risk Companies.

Tribunal remanded the matter to the TPO to consider comparable and also held that what are the circumstances the turnover cap, goodwill, loss making companies, size and economies of sale, high risk companies can be said to be comparable. (AY. 2011-12, 2012-13)