Pyramid IT Consulting (P.) Ltd. v. ACIT (2019) 264 Taxman 23 (Delhi) (HC)

S. 92C : Transfer pricing–Arm’s length price-Only one comparable-Difference in functionality- Matter remanded.

Court held that since the entire TP Adjustment has hinged only on one comparable, the objection to the inclusion of which by the assessee required a detailed consideration, the impugned order cannot be sustained in law. Accordingly the entire issue of determining the TP adjustment in respect of the transactions in the staffing segment of the assessee should be considered afresh by the TPO uninfluenced by his earlier order. (AY. 2010-11)