Dissimilar Firms were excluded from selected comparables while doing TP analysis u/s 92

PCIT Vs Fluor Daniel India Pvt Ltd (Delhi High Court)

Conclusion: AO was directed to exclude certain comparable companies in view of highly technical capabilities of executing infrastructure development projects vis-a-vis that of assessee who was rendering engineering and related services as a sub­contract limited to specific functions as per the requirement of its affiliate.

Held: Assessee had declared an income of ₹198 Cr for the Assessment Year(AY) 2011-12 and reported a total sum of ₹1224 Cr as international transactions. I

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