Held, that the companies whose turnover in the current year more than Rs. 200 crores should be excluded from the list of comparable companies as the turnover of the assessee company in the current year was less than Rs. 200 crores but in the earlier two years its turnover was more than Rs. 200 crores. Therefore, the Transfer Pricing Officer was directed to take the margins of this company for financial year 2015-16. (AY. 2016-17).
Aurigo Software Technologies P. Ltd. v. ITO (2022)98 ITR 294 (Bang) (Trib)
S. 92C : Transfer pricing-Arm’s length price-Selection of comparables-Turnover more than 200 crores-Assessee company making less than 200 crores in current year-Margin of current year alone to be taken. [S. 92A]