Tribunal held that if an extraordinary event has taken place by way of amalgamation in a company, that company cannot be considered as a comparable. Related party transaction of selected company exceeded limit of 25 per cent, said company be excluded from comparable list. Where turnover of selected company was almost 80 times more than turnover of assessee-company, said company could not be selected as comparable. (AY. 2015-16)
Entercoms Solutions (P.) Ltd. v. ACIT (2022) 192 ITD 685 (Pune)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Abnormal events-If an extraordinary event has taken place by way of amalgamation in a company, that company cannot be considered as a comparable-.R-elated party transaction of selected company exceeded limit of 25 per cent, said company be excluded from comparable list-turnover of selected company was almost 80 times more than turnover of assessee-company, said company could not be selected as comparable.