The Tribunal held that the Transfer Pricing Officer had excluded companies having turnover of less than Rs. 1 crore but did not put an upper limit to the turnover for exclusion of companies having high turnover. High turnover companies could not be compared to the assessee. The Transfer Pricing Officer was directed to exclude companies having turnover in excess of Rs. 200 crores. (AY. 2014-15)
Xchanging Solutions Ltd. v.Dy. CIT (2022)96 ITR 544 (Bang) (Trib)
S. 92C: Transfer pricing-Arm’s length price-Comparables-Companies with turnover in excess of Rs. 200 Crores-Not comparable.