Dissimilar Firms were excluded from selected comparables while doing TP analysis u/s 92

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...