Tribunal held that ,while selecting a comparable, TPO had not looked into functions of comparable and TPO’s own filters were not proportionate with range of 75 – 85 per cent (freight cost/freight income) applied for selection of comparables. Tribunal directed to exclude said comparable from list of comparables. (AY. 2007 -08 to 2012 -13)
CEVA Freight India (P.) Ltd. v. DCIT (2019) 176 ITD 341 (Delhi) (Trib.)
S. 92C : Transfer pricing-Arm’s length-Selection of comparable-TPO’s own filters were not proportionate with range of 75 – 85 per cent (freight cost/freight income)-Directed to exclude said comparable from list of comparables.