Shanti Prime Publication Pvt. Ltd.
Section 92CA of the Income Tax Act, 1961 — Transfer Pricing — Computation of arms length price — Selection of comparables — Large companies and functionally distinct with different areas of development and services cannot be benchmarked or equated with assessee, thus, excluded from the list of comparables —Principal Commissioner of income tax vs. Symphony Marketing Solutions India P. Ltd. [2019] 417 ITR 289 (Delhi)