Delhi HC: Exclusion of OTL Comparable – ITAT to Decide

UOP India Private Limited Vs PCIT 9 (Delhi High Court) Introduction: The case of UOP India Private Limited Vs. PCIT (Delhi High Court) revolves around the exclusion of Onward Technologies Limited (OTL) as a comparable in a transfer pricing study. The Income Tax Appellate Tribunal (ITAT) was directed by the Delhi High Court to reconsider this exclusion under Section 254 of the Income Tax Act, 1961. Detailed Analysis 1. Background of the Case The case involves the transfer pricing study of UOP India Private Limited. The Transfer Pricing Officer (TPO) initially accepted OTL as a comparable in the...