Companies with similar functionality can be compared while valuing international transaction

Facebook India Online Services Private Limited Vs DCIT (ITAT Hyderabad) ITAT Hyderabad held that for comparability of company with that of the assessee, in case of international transactions, the criteria of functionally comparability needs to be considered. Facts- During the year the assessee has entered into various international transactions with its AE. After going through TP documents of the assessee, TPO had rejected the TP study of assessee and had given show cause notice to the assessee dated 20.10.2017 as he had found that transactions were not at arm’s length. Thereafter, Trans...