Internal comparability is a preferred method in transfer pricing study where within company profit margin data with third parties available

Brief of the Case ITAT Bangalore held In the case of M/s. Agila Specialties Pvt. Ltd vs. DCIT that when the data is available showing profit margin of that enterprise itself from a third party, it is always safe and advisable to adopt internal comparable. The reason is that the various factors having bearing on the quality of output. assets employed, input cost etc. continue to remain by and large same in case of an internal comparable.The effect of difference due to such inherent factors on comparison made with the third parties, gets neutralized when comparison is made with internal comparab...