Dismissing the appeal of the revenue the Court held that, companies large and functionally distinct with different areas of development and services, cannot be benchmarked or equated. Accordingly the exclusion of three comparables is Held to be valid. No question of law. (AY. 2009-10, 2010-11)
CIT v. Symphony Marketing Solutions India P. Ltd. (2019) 417 ITR 289 (Delhi)(HC)
S. 92C : Transfer pricing–Arm’s length price–Comparables-Companies large and functionally distinct with different areas of development and services-Cannot be benchmarked or equated-Exclusion of three comparables-Held to be valid. [S. 92CA]