Galax E Solutions India (P.) Ltd. v. ACIT (2022) 192 ITD 326 (Bang.)(Trib.)

S. 92C : Transfer pricing-Arm’s length price-Turnover-Comparable-Companies having turnover of more than 200 crores upto 500 crores have to be regarded as one category and said companies cannot be regarded as comparables with companies having turnover of less than 200 crores.

Tribunal held that while choosing companies as comparable companies in determination of ALP in transfer pricing cases and companies having turnover of more than 200 crores upto 500 crores have to be regarded as one category and those companies cannot be regarded as comparables with companies having turnover of less than 200 crores.  (AY. 2013-14)