Tribunal held that threshold limit for application of RPT filter should be 15 per cent and in cases where available samples are less, then threshold limit can be fixed at 25 per cent. Therefore, directions of DRP fixing threshold limit as 0% for application of RPT filter was not correct. (AY.2010-11)
ITO v. Sabre Travel Technologies (P.) Ltd. (2020) 185 ITD 617 (Bang.)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Threshold limit for application of RPT filter cannot be fixed as zero per cent-15% to 25%.