Dismissing the appeal of the Revenue the Court held that comparison has to be made between two equals. Where assessee-company was engaged in rendering research and technical services and had started its business in relevant financial year, it could not be compared with companies which were doing business for many years. (AY. 2008-09)
PCIT v. Radhashir Jewellery Co. (P.) Ltd (2024) 298 Taxman 754 (Bom)(HC)
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Research and technical services-Comparable-Multi year data-Cannot be compared with companies which were doing business for many years. [S. 260A]