Comparable with functional and risk profiles difference cannot be selected

M/s. Mckinsey Knowledge Centre India pvt. Ltd. Vs PCIT (Delhi High Court)

The revenue urged that a stringent application of the comparability test was unnecessary as was also provisioned in Chapter-6 of United Nations Practical Manual on Transfer Pricing, Edition 2013, and some flexibility in conducting this comparison was urged to be allowed.

However, from the above analysis, in the present appeals, even if due consideration is given to a certain level of dissimilarity between the Assesse

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