Recently, the Delhi High Court in its verdict in the case of Chryscapital Investment Advisors (India) Private Limited emphasised functional analysis as the key comparability criteria, and inter-alia held that:
- merely earning high profits/ losses could
not be a reason to exclude a company as a comparable; and
- for the purpose of comparability analysis,
data of multiple years could be used only when such data has an influence
on the transfer price of the transaction under consideration.
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