Functionally dissimilar entity not includible as comparable: Delhi HC

Sequential Technology International India Pvt Ltd Vs ACIT (Delhi High Court)

Delhi High Court held that passing of order without considering the contention of the assessee that entity that is functionally dissimilar could not be included as a comparable not justified. Accordingly, matter restored back to TPO.

Facts- The assessee has filed the present appeal u/s. 260A of the Income Tax Act, 1961 impugning an order dated 15.10.2018 passed by the learned Income Tax Appellate Tribunal in respect of the assessment year (AY) 2013-14. The assessee had filed the sai

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