Assessee-company is engaged in rendering engineering design services to AE. Tribunal held that a Government company which was huge and fast in terms of function performed, risk assumed and assets owned, was not acceptable as valid comparable.High Court affirmed the Order of Tribunal. (AY. 2011-12)
PCIT v. Fluor Daniel India (P.) Ltd. (2022) 134 taxmann.com 356 (Delhi)(HC) Editorial : Notice is issued in SLP filed by the revenue; PCIT v. Fluor Daniel India (P.) Ltd. (2022] 285 Taxman 280 (SC)
S. 92C : Transfer pricing-Arm’s length price-Exclusion of comparable-Functionally assets and risk test-Order of Tribunal is affirmed. [S. 260A]