Allowing the appeal the Tribunal has followed the rule of constancy and rejected the comparable adopted by the TPO on the ground that the comparable adopted by the TPO is in different business hence cannot be comparable.( AY.2007-08)
Exxon Mobil Company India P. Ltd. v. ACIT (2018) 65 ITR 583 /196 TTJ 1070 / 97 taxmann.com 43 (Mum.)(Trib.)
S. 92C : Transfer pricing-Arm’s length price—Comparables-Providing back office support services-Followed rule of consistency -Different business hence cannot be comparable. [S. 92CA ]