TP provisions requires comparison of a controlled transaction with uncontrolled transaction, comparison within two controlled transaction is immaterial

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 complet...