Principle governing identification of comparable transactions would be same, irrespective of TP method

Infogain India Pvt Ltd Vs DCIT (ITAT Delhi) Conclusion: Comparison of activities undertaken /functions performed was important for determining the comparability between controlled and uncontrolled transactions/entity. It would not be opposite to ignore functional dissimilarity only for the reasons that its impact may be reduced on account of using arithmetical mean of the profit level indicator. The principle governing the identification of comparable transactions would be the same, irrespective of whichever transfer pricing method is adopted. Held: Assessee-company was established as a back-e...