Case Law Details
Brief of the Case
ITAT Mumbai held In the case of Greaves Cotton Ltd. vs. ITO that under the transfer pricing regulations, a comparability analysis is a comparison of a controlled transaction with uncontrolled transaction and they are comparable if none of the difference between transactions could effect the factors like price or margin. If there are some differences then a reasonable accurate adjustment can be made to eliminate the material effect of any such difference. In this case the TPO has carried out comparative analysis by adopting internal transactions with two AEs, which are completely controlled and related party transactions, hence, such a comparability analysis at the threshold is liable to be rejected.
Facts of the Case
The assessee is a Public Limited Company engaged in the business of manufacture and sale of marine and industrial gear boxes, diesel engines, generating sets, Tandem Rollers, Transit Mixture, Vibratory Compactors etc. and also trade in steam traps, pumps, fluid coupling and crucibles etc.
Disallowance u/s 14A
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