Held, that the Dispute Resolution Panel was justified in its directions that the turnover filter was to be applied and only those companies having turnover of more than Rs. 200 crores and less than Rs. 2,000 crores were to be taken as comparable for the purpose of the transfer pricing study. (AY. 2011-12).
Dy. CIT v. Harman Connected Services Corporation India Pvt. Ltd. (2023)101 ITR 3 (SN)(Bang) (Trib)
S. 92C : Transfer pricing-Arm’s length price-Selection of comparable-Turnover filter-Turnover of assessee 332 crores-DRP is justified in directing turnover of 200 crores to 2000 crores-Multiple of 10 times turnover could not be adopted. [S.92CA]