ITAT Excludes Manufacturing Companies as Comparables as Assessee Was Predominantly a Trader

DCIT Vs 3M India Limited (ITAT Bangalore) The Income Tax Appellate Tribunal Bangalore dismissed the Revenue’s appeals for Assessment Years 2008-09 and 2009-10 in a transfer pricing dispute involving exclusion of certain comparables and adjustment relating to IT support services. The assessee company was engaged in manufacture, conversion, and trading of diversified products. The dispute primarily related to the healthcare segment, where the assessee reported an operating profit margin of 2.90% on sales. The assessee had selected five comparable companies with an arithmetic mean margin of 2.8...