Wrong Comparables Out, Right Comparables In – Netting of Payables Allowed

Stryker India Private Limited Vs ACIT (ITAT Delhi) Wrong Comparables Out, Right Comparables In – Netting of Payables Allowed, Stryker’s TP Case Remanded-ITAT Delhi Tribunal ruled that comparables must reflect true functional similarity. Interest adjustment on delayed receivables remanded, with direction to allow netting off against payables with AEs. Stryker India Pvt. Ltd., a wholly owned subsidiary of Stryker Far East Inc., Hong Kong, engaged in distribution of medical/surgical products &  provision of marketing support services, challenged Transfer Pricing (TP) adjustments made by ...