Transfer Pricing- Comparables have to be compared on similar standards

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. ...