Transfer Pricing- Low Turnover Companies can not be taken as comparable, Only operational profits to be considered for comparison

DHL Express (India) Pvt Ltd Vs. ACIT (ITAT Mumbai)- The assessee’s argument that com parables with a turnover less than 20% of the assessee’s turnover should be considered is not acceptable because it is a universal fact that there are lot of differences between large businesses and small businesses operating in the same field. The argument that segmental results of a company engaged in diverse activities should be considered is also not acceptable because in such results certain expenditures, particularly relating to interest and head offi

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