Weatherford Drilling and Production Services (India) Pvt. Ltd. v ACIT (2022)100 ITR 46 (SN)(Ahd) (Trib)

S. 92C : Transfer pricing-Arm’s length price-Comparable-Functionally not comparable-Excluded from the list of comparbles. [S.92CA]

Held that  a company which does most of these activities through its own employees is not functionally comparable to a company which outsources the majority of its work to third party vendors. In view thereof, CTIL should be excluded from the list of comparables, since CTIL was functionally different from the assessee-company.(AY.2008-09)