Transfer Pricing- Companies having abnormal cost cannot be taken as comparable

Adjustment can be made in the assessees own profit margin in TP case to make it comparable provided there should not be any extraordinary and abnormal differences Brief of the case: Assessee had reduced its operating expenses to calculate ratio of operating profit/Total cost which was the base to calculate the value of export of goods in transfer pricing on the basis that it was its first year of operation and the initial cost  would be high which will not incur in the forthcoming years of operation. But The AO/TPO had not accepted the assessee’s decision on the basis that the adjustment ca...