Comparable which is to be considered as a benchmark for comparing with comparable company should belong to year under consideration

Brief of the case: Punjab & Haryana High Court held in CIT Vs DSM Anti Infectives India ltd that the benchmark comparable which was used to compare with the comparable company that should be considered only of that year of which TP case was involved. In other words if any comparable point which was used in comparing with the comparable company for international transactions did not remain comparable point in any other year then, it did not mean that that company did not remain comparable anymore for that particular year. Moreover the percentage of the raw material of total sales consumed b...