Delhi High Court Upholds Exclusion of Comparables in Transfer Pricing Case

PCIT Vs Qualcomm India Pvt Ltd (Delhi High Court)

Delhi HC Upholds exclusion of Comparables for functional dissimilarity & significant difference in turnover

In a recent case, the Delhi High Court upheld the exclusion of comparables due to functional dissimilarity and significant differences in turnover. The case, titled “PCIT vs. Qualcomm India Pvt Ltd,” for the Assessment Year 2014-15, focused on the transfer pricing matter. The court excluded three comparables: Infobeans Technologies Ltd, Cybercom Datamatics Information Solutions Ltd, and Infosys BPO Ltd, citing clear reasons for their exclusion.

Detailed Analysis

The Delhi High Court examined the exclusion of three comparables and the adjustment for interest on receivables:

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