Allowability of use of Extrapolated Data for comparables inspite of having different year-end in ITeS transfer pricing dispute

Goldman Sachs (India) Securities Pvt. Ltd Vs Assessment Unit (ITAT Mumbai) Conclusion: While computing arm’s length price (ALP), it is required both the tested party and the comparable should have similar financial year endings for proper analysis of the functions performed, assets employed and risks assumed. The company, which was otherwise functionally similar, could not be rejected as a comparable merely on the basis that its accounts were maintained with a different financial year ending, provided that results for the relevant financial year could reasonably be extrapolated from the ...