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).

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