Loss or low profit cannot be reason for exclusion of comparables for computing ALP: ITAT Mumbai

Star Television Entertainment Ltd. Vs DCIT (ITAT Mumbai) ITAT Mumbai held that exclusion of comparables for the reason that those companies are loss making or low profit making is not correct. Accordingly, TPO directed to include these comparables and re-compute the Arm’s Length Price (ALP). Facts- The assessee is a non resident company and is a tax resident of Hong Kong belonging to the Star Television group of companies. The case of the assessee was selected for scrutiny and statutory notices were duly served on the assessee. A reference was made to the Transfer Pricing Officer (TPO) in or...