Court held that the Tribunal was justified in excluding the two comparables, which were included by the Transfer Pricing Officer for determination of the arm’s length price under section 92B, on the ground of functional dissimilarities. Order of Tribunal affirmed. (AY.2012-13)
PCIT v. Inductis India Pvt. Ltd (2023) 157 taxmann.com 87 / (2025) 483 ITR 492 (Delhi)(HC) Editorial: PCIT v. Inductis India Pvt. Ltd [2025] 175 taxmann.com 423 (SC), SLP dismissed on account of delay of 387 days.
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Interest on delayed receivables-Selection of comparables-Exclusion of comparables by Tribunal on ground of functional dissimilarities-Order of Tribunal affirmed. [S.92B, 92CA]
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