Conexant Systems Private Ltd. v. Dy. CIT (2018) 63 ITR 320 (Hyd)(Trib.)

S. 92C : Transfer pricing – Arms’ length price – Extraordinary event occurred in the case of comparable companies is liable to be excluded. [ S.92CA ]

Appellate Tribunal held that as there was a specific direction of the Panel that the companies in which there were extraordinary events should be excluded, the AO was to verify the extraordinary event in the case of comparable company and to exclude the same if it is found that any extraordinary event had occurred in its case. (AY. 2010-11)