No comparables to be selected in ALP determination if comparables differs in turnover

NXP India Pvt. Ltd. Vs DCIT (ITAT Bangalore) Conclusion: Exclusion of comparables from the list of comparables on basis of turnover, functional difference for determination of Arms Length Price was valid. Held: Assessee-company was engaged in the activities in India, which included design and sales agent support services NXP’s design competence centre in Bangalore offered user solutions for vibrant media technologies and focused on automotive, identification and software businesses. For the above determination of Arms Length Price (ALP), assessee selected 25 comparables, however, TPO lim...