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Transfer Pricing- Comparables have to be compared on similar standards
Case Law Details
- Case Name
- Gsys Inteenigrating System (India) Pvt. Ltd. Vs DCIT (ITAT Bangalore)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All ITAT, ITAT Bangalore
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Genisys Integrating System (India) Pvt. Ltd. Vs DCIT
Decided by- ITAT Bangalore
Decided on- 5th Aug 2011
Appeal No. -IT 1231/BANG-2010
Summary and relevant extract from of the above case law-
All the com parables have to be compared on similar standards and the assessee cannot be put in a dis-advantageous position, when in the case of other companies adjustments for under utilisation of manpower is given. The assessee should also be given adjustment for under utilisation of its infrastructure. The AO shall consider this fact also while determining the ALP and make the TP adjustments.
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