Companies, whose employees or directors are involved in fraud, should not be accepted as comparable

In this view of the matter we set aside the issue of determining the transfer pricing in accordance with the directions in respect of specific comparables referred to above as well as taking into consideration the following:

(a) The companies which are functionally dissimilar unless segmental results in respect of comparable line of activity available.

(b) In case of comparable companies foreign exchange loss or gain have been taken into account in computing the profit, in the

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