AE cannot be considered as comparable as it lacks independent nature of uncontrolled transaction

Corteva Agriscience Services India Private Limited Vs ACIT (ITAT Hyderabad) We straight away come to the assessee’s sole substantive grievance canvassed in the instant appeal challenging correctness of both the lower authorities’ action making arms length price adjustment of Rs.59,45,094/- in the assessment order going by S.B.I’s 14.45% interest rate; and that too, without adopting any segmental comparable in the assessee’s segment of business support services. We next note with able assistance of both the parties that the Transfer Pricing Officer’s order dated 31.10.2016 in para 6.5...