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Transfer Pricing Adjustment Overturned Due to Improper Comparable Selection
Case Law Details
- Case Name
- FIL India Business & Research Services Pvt. Ltd. Vs Assessment Unit (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2020-21
- Courts
- All ITAT, ITAT Delhi
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FIL India Business & Research Services Pvt. Ltd. Vs Assessment Unit (ITAT Delhi)
TP Comparable Fails Its Own Turnover Filter: ITAT Delhi Orders Fresh ALP Re-Work & Deletes PF Disallowance
FIL India Business & Research Services Pvt Ltd, engaged in software development, IT-enabled services & research support services, filed appeal against the final assessment order u/s 143(3) r.w.s. 144C(13). The DRP had upheld major Transfer Pricing adjustments & certain corporate tax additions.
Transfer Pricing – Comparable Rejected
The key issue was a TP adjustment of ₹14.56 crore in t...




