Functionally comparable company cannot be excluded from Comparables for non-disclosure of RPT

EMC Software & Services India Pvt. Ltd. Vs. JCIT (ITAT Banglore) The assessee seeks inclusion of T2T2 India Ltd. The Ld. A.R. submitted that this company is functionally comparable company. The TPO/DRP has rejected the same only for the reason that the detail of Related Party Transactions (RPT) was not disclosed in the Annual Report. The Ld. A.R. submitted that the above said company would have disclosed RPT transactions if any such transactions were available. Since no disclosure was made, it has to be concluded that there was not RPT transaction., Accordingly the Ld. A.R. submitted that ...