Dismissing the appeal of the revenue the Court held that; A company which outsources its work is not comparable for ALP determination with a company that does activity inhouse. A company having substantial related party transactions, could not be selected as comparable. ( AY. 2003-04)
PCIT v. Pfizer Ltd. (2019) 262 Taxman 215/ 308 CTR 389/ 177 DTR 110 (Bom.)( HC)
S. 92C : Transfer pricing–Arm’s length price-Company which outsources its work is not comparable for ALP determination with a company that does activity inhouse-A company having substantial related party transactions, could not be selected as comparable.