Transfer Pricing: Functionally different companies cannot be taken as comparable

M/s. Enchanting Travels Pvt. Ltd. Vs The Income Tax Officer (ITAT Bangalore)

We find that TPO has already taken the total 10 comparables and with respect to 8 comparables, assessee has no objections. With respect to Kerala Travels Interserve Ltd., we have carefully perused its financial statements and we find the main revenue is from different activities and not from the tour operations. Therefore, Kerala Travels Interserve Ltd., cannot be held to be the good comparable and we accordingly direct the AO/TPO to exclude this company from the list of comparables.

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