Comparability Analysis must Focus on Functional Similarity Over Product Matching: Delhi HC

PCIT Vs Future First INFO. Services Pvt. Ltd. (Delhi High Court) In the case of PCIT Vs Future First INFO. Services Pvt. Ltd., the Delhi High Court examined several issues concerning transfer pricing, the comparability analysis of international transactions, and tax disallowances under the Income Tax Act. The revenue challenged the decision of the Income Tax Appellate Tribunal (ITAT), which had partly allowed the assessee’s appeal and excluded certain comparables in the determination of Arm’s Length Price (ALP) for the services provided by the assessee to its associated enterprises...