Comparables should be selected after detailed analysis and any adjustment to ALP can be made only on the basis of firm calculation and back-up data

Court: Income Tax Appellate Tribunal Citation: ACIT Vs. Vedaris Technologies (Pvt.) Ltd. [2010-TII-10-ITAT-DEL-TP] Brief:- Overview:- The Delhi Bench of Income Tax Appellate Tribunal (“the Tribunal”) in its recent ruling in the case of ACIT v. Vedaris Technologies (Pvt.) Ltd [2010-TII-10-ITAT-DEL-TP] has held that selection of comparable uncontrolled transactions (“comparables”) for determining arm’s length price (“ALP”) should be done with reference to Rule 10C(2) of the Income-tax Rules, 1962 (“the Rules”). The Tribunal also asserted that...