Sec. 92C of Income Tax Act, 1961—Transfer Pricing— Selection of comparables - Company having extraordinary high turnover cannot be selected as comparable.

Facts: The entire dispute revolves around the inclusion and exclusion of certain comparables while determining the ALP in respect of international transactions with AE.

Held, that Company selected is not a proper comparable on account of (i) risk profile, (ii) revenue & ownership of branded products, (iii) R 85 D expenses, (iv) Onsite v. Offshore operations, (v) Expenditure on Advertisement/Sale promotion & brand building, thus, AO/TPO is directed to exclude it from the final set of comparables. Comparable company was excluded because of its abnormal profit in the same year. - NAGARRO SOFTWARE (P.) LTD. V/s ITO - [2020] 182 ITD 128 (ITAT-DELHI)