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Dissimilar Firms were excluded from selected comparables while doing TP analysis u/s 92
Case Law Details
- Case Name
- PCIT Vs Fluor Daniel India Pvt Ltd (Delhi High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2011-12
- Courts
- All High Courts, Delhi High Court
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PCIT Vs Fluor Daniel India Pvt Ltd (Delhi High Court)
Conclusion: AO was directed to exclude certain comparable companies in view of highly technical capabilities of executing infrastructure development projects vis-a-vis that of assessee who was rendering engineering and related services as a subcontract limited to specific functions as per the requirement of its affiliate.
Held: Assessee had declared an income of ₹198 Cr for the Assessment Year(AY) 2011-12 and reported a total sum of ₹1224 Cr as international transactions. It used the transactional net margin method (TNMM) to determine...
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