TP – Super profit making or Restructured Companies cannot be taken as comparables for computing ALP

 ITAT HYDERABAD BENCH ‘A’ Capital IQ Information Systems (India) (P.) Ltd. versus Deputy Commissioner of Income-tax (International Taxation) IT Appeal NO. 1961 (HYD.) of 2011 [ASSESSMENT YEAR 2007-08] Date of Pronouncement- 23.11.2012 ORDER Saktijit Dey, Judicial Member This appeal by the assessee arises out of the assessment order dated 11.10.2011 passed under S.143(3) read with S.144C of the Act, on the directions of the Dispute Resolution Panel(DRP). The appeal pertains to the assessment year 2007-08. 2. The factual matrix as emanates from the record are the a...