Significant differences in product segments & marketing strategies: ITAT excludes comparable

PCIT Vs Oriflame India Pvt Ltd (Delhi High Court) Introduction: The case of PCIT vs. Oriflame India Pvt Ltd before the Delhi High Court involved the Income Tax Appellate Tribunal’s (ITAT) reconsideration of Transfer Pricing Officer’s (TPO) proposed income adjustments. The dispute revolved around the exclusion of Modicare Limited as a comparable entity and the method of benchmarking. Detailed Analysis: Oriflame India Pvt Ltd, a subsidiary of Oriflame International SA, engaged in selling skincare and cosmetic products, faced international transaction scrutiny with associated enterpri...