Held that functionally distinct with different areas of development and services cannot be benchmarked. The Assessing Officer is directed to exclude two comparables and include one comparable based on appreciation of evidence. (AY.2012-13)
Sas Research and Development (India) Pvt. Ltd. v. Dy.CIT (No. 1) (2022) 93 ITR 482 (Pune)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Arm’s Length Price-Comparables-Functionally distinct with different areas of development and services-Cannot be benchmarked-Directed to exclude two comparables and include one comparable based on appreciation of evidence. [S. 92CA]