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| The Tax Publishers2022 TaxPub(DT) 5227 (Delhi I-1 Bench) : (2022) 097 ITR (Trib) 0687 INCOME TAX ACT, 1961
Section 92C
While the assessee was in manufacturing of setup boxes, BCH Electric Ltd. was a well recognized, switchgear and low voltage panel manufacturer of low voltage electrical and electronic control. Hence, it was not functionally comparable to assessee.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity
Assessee engaged in manufacturing and assembling of set up boxes. Entered into an international transaction with its AE for purchase of raw material. TPO considered BCH Electric Ltd. as comparable to assessee's case. Held: While the assessee was in manufacturing of setup boxes, BCH Electric Ltd. was a well recognized, switchgear and low voltage panel manufacturer of low voltage electrical and electronic control. Hence, it was not functionally comparable to assessee.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
INCOME TAX ACT, 1961
Section 92C
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