HC Upholds Exclusion of Comparables Due to Functional Dissimilarity & Amalgamation

CIT Vs GE India Business Services Pvt. Ltd. (Delhi High Court) The Delhi High Court recently passed a judgment in a transfer pricing case involving GE India Business Services Pvt. Ltd. The appeal was against the order of the Income Tax Appellate Tribunal (ITAT) for the Assessment Year 2010-11. The key issue was the exclusion of four comparables by the Tribunal for benchmarking international transactions related to offshore outsourcing services provided by the taxpayer to its associated enterprises (AEs). The appellant/revenue argued that the Tribunal wrongly excluded the comparables based on f...