For TP comparability, functional similarity and scale of operations were crucial; inclusion of low-turnover comparable was set aside

PCIT-1 Vs American Express (India) Pvt. Ltd. (Delhi High Court) Conclusion: Where ITAT directed inclusion of Cepha Imaging Pvt. Ltd. as a comparable solely on the basis that it satisfied the export turnover filter without examining its functional comparability with assessee, and further directed inclusion of CG Vak Software & Exports Ltd. despite a substantial disparity in turnover between assessee and the comparable, High Court held that functional similarity was a fundamental requirement for comparability analysis and that significant differences in scale and turnover may render an enti...