Transfer Pricing- Low Turnover Companies can not be taken as comparable, Only operational profits to be considered for comparison

DHL Express (India) Pvt Ltd Vs. ACIT (ITAT Mumbai)- The assessee’s argument that com parables with a turnover less than 20% of the assessee’s turnover should be considered is not acceptable because it is a universal fact that there are lot of differences between large businesses and small businesses operating in the same field. The argument that segmental results of a company engaged in diverse activities should be considered is also not acceptable because in such results certain expenditures, particularly relating to interest and head office, are generally not allocated. When direct com p...