Held that companies whose segmental data not available, having functional disparity with assessee, undergoing extraordinary event of amalgamation are to be excluded from list of comparables. That service tax refund or service tax written back was operating revenue while computing profit level indicator. (AY.2010-11)
Tech Mahindra Business Services Ltd. v. ACIT (2024)112 ITR 21 (SN)(Mum)(Trib)
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Selection of comparables-Companies whose segmental data not available, having functional disparity with assessee, undergoing extraordinary event of amalgamation are to be excluded from list of comparables-Profit level indicator-Service tax refund or service tax written back is operating revenue.[S. 144C(13)]