Arm’s length price should be based on the functional and asset profile of the company

Court  Mumbai Bench of the Income Tax Appellate Tribunal Citation: ITO Vs. Zydus Altana Healthcare Pvt. Ltd. [2010-TI I-29-ITAT–MUM-TP] Brief- The Mumbai Bench of the Income Tax Appellate Tribunal (‘the Tribunal’), in the case of ITO Vs. Zydus Altana Healthcare Pvt. Ltd. [2010-TI I-29-ITAT–MUM-TP], while deciding the case in favor of the assessee, ruled that the determination of arm’s length price should be based on the functional and asset profile of a company and profit margins earned by comparable companies should be adjusted for functional differences between the tes...