In Computation of ALP, company having large related party transactions or being functionally different from assessee cannot be taken as comparable

ITAT MUMBAI BENCH ‘K’ Sandstone Capital Advisors (P.) Ltd. versus Assistant Commissioner of Income-tax IT APPEAL NO. 6315 (MUM.) OF 2012 [ASSESSMENT YEAR 2008-09] FEBRUARY 6, 2013 ORDER Vijay Pal Rao, Judicial Member This appeal by the assessee is directed against the assessment order dated 28.9.2012 passed u/s 143(3) r.w.s 144C(13) in pursuant to the directions of the DRP u/s 144C(5) of the I T Act for the AY 2008-09. 2. The only ground raised by the assessee in this appeal is as under: “On the facts and circumstances of the case and in law, the Assessing Of...