Assessee having a turnover of Rs. 33.24 crores cannot be compared with the companies having turnover ranged from Rs. 207 crores to Rs. 3,032 crores. Matter remanded to for applying turnover filter for selection of 0 to 200 crores.
Kumaran Systems (P.) Ltd. v. DCIT (2021) 191 ITD 514 (Chennai) (Trib.)
S. 92C : Transfer pricing-Arm’s length price-Comparable-Turnover filter-Having small turnover-Cannot be compared with giant companies having huge turnover-Matter remanded.