Transfer Pricing – Pygmies Not Comparable With Giants

DCIT Vs Deloitte Consulting India Pvt. Limited (ITAT Hyderabad)- Risk adjustment disallowed, impact of intangibles on pricing negated, taxpayer estopped from subsequently pointing facts having material bearing, application of export earnings filter approved, etc. The Tribunal ruled upon several matters including allowance of risk adjustment, impact of intangibles on profit, use of turnover criteria for selection of com-parables, use of current year data, use of export sales criteria for selection of com-parables, whether or not a taxpayer can point out facts (not brought out earlier) which ha...