Exclusion of Comparables Unjustified if Financial Data Can Be Reasonably Extrapolated: ITAT

Syngenta Services Private Limited Vs ACIT (ITAT Mumbai) Introduction: In a recent judgment, the Income Tax Appellate Tribunal (ITAT) Mumbai provided significant clarity on the treatment of comparables in transfer pricing assessments, particularly when financial data is available but needs extrapolation. The case in question, Syngenta Services Private Limited Vs. ACIT, centered on the taxpayer’s challenge against the assessment order that included and excluded certain comparables for benchmarking international transactions. Detailed Analysis: Syngenta Services Private Limited, engaged in ...