Comparable Selection for Arm’s Length Price Relies on Functional Similarity

Alcatel Lucent India Limited Vs DCIT (Delhi High Court) Inclusion/ Exclusion of comparable to determine Arm’s Length Price depends on similarity of functional filters & business model for arriving at ALP Conclusion: Inclusion/ exclusion of certain uncontrolled entities as comparable for purpose of determining arm’s length price (ALP) of assessee company/ Appellant depends on similarity of functional filters, product homogeneity and business model, in order to arrive at suitable comparable for determination of arm’s length price. Hence, the matter was remanded back to the...