Pune Tribunal Removes Specific Entities From Transfer Pricing Comparative Analysis

The Income Tax Appellate Tribunal in Pune adjudicated a transfer pricing controversy valued at ₹2.09 crore for assessment year 2015-16, directing the removal of SPI Technologies, AGS Health, and Infosys BPO from the set of ITES comparables. The tribunal based its exclusion on distinct structural anomalies such as business mergers, significant related party transactions, and disparate turnover scales that distorted fair comparison.

Transfer pricing adjustments often hinge on selecting appropriate benchmark companies to evaluate arm's length pricing for international transactions. By removing entities with unique operational profiles or corporate restructurings, the tribunal ensured a more accurate financial benchmarking for the taxpayer's operational sector.

Tax professionals handling transfer pricing litigations must review their benchmarking studies against these criteria to align with tribunal standards. The Assessing Officer is required to recalculate the adjustments in accordance with the revised set of comparables.