Philips Medical Systems Private Ltd (now merged with Philips Electronics India Ltd.). v. ITO (2018) 196 TTJ 1031 (Kol.)(Trib.)

S. 92C : Transfer pricing-Functionally different company cannot be selected as a comparable for arriving ALP of an international transaction.

Tribunal held that Functionally different company cannot be selected as a comparable for arriving ALP of an international transaction. (AY.2002 -03)