Transfer pricing –Comparable cannot be selected if risk assumed and capital employed in international transactions are unmatched

IN THE ITAT PUNE BENCH ‘B’ Hoganas India (P.) Ltd. versus Deputy Commissioner of Income-tax IT Appeal No. 1463 (Pune) of 2010 [ASSESSMENT YEAR 2006-07] JANUARY 11, 2013 ORDER R. S. Padvekar, Judicial Member This appeal is filed by the assessee challenging the assessment order dated 7.10.2010 passed under section 143(3) of the Income-tax Act, 1961 read with directions under section 144C(5) of the Act for assessment year 2006-07. The assessee has taken the following grounds (revised) in the appeal:- 1.1 The ld. Assessing Officer erred in assessing the total income ...