U.L. India Pvt. Ltd. v. Dy. CIT (2022)96 ITR 191 (Trib)(Bang) (Trib)

S. 92C : Transfer pricing-Arm’s length price-Having high turnover-Turnover is a relevant criterion for choosing comparable [R. 10B]

In the matter where the Dispute Resolution Panel excluded uncontrolled comparables having turnover more than Rs. 200 crores in the absence of turnover criterion prescribed in rule 10B of the Income-tax Rules, 1962, and there is no correlation between turnover and profit margin, it was held that the turnover was a relevant criterion for choosing comparable companies. (AY. 2010-11, 2011-12)