Comparable Selection for Arm’s Length Price Relies on Functional Similarity

Alcatel Lucent India Limited Vs DCIT (Delhi High Court)

Inclusion/ Exclusion of comparable to determine Arm’s Length Price depends on similarity of functional filters & business model for arriving at ALP

Conclusion: Inclusion/ exclusion of certain uncontrolled entities as comparable for purpose of determining arm’s length price (ALP) of assessee company/ Appellant depends on similarity of functional filters, product homogeneity and business model, in order to arrive at suitable comparable for determination of arm’s length price. Hence,

Please become a Premium member. If you are already a Premium member, login here to access the full content.