Sunday, January 18, 2026

Income Tax and Selection of Comparable Companies for Benchmarking the International transaction

Income Tax and Selection of Comparable Companies for Benchmarking the International Transaction 

In the recent decision dealing with selection of comparable companies, it has been concluded that since Satyatej Commercial Co. Ltd. continues to have similar functional attributes as in the preceding year, TPO/AO was directed to consider Satyatej Commercial Co. Ltd. as comparable to the assessee for benchmarking the international transaction of purchase of finished goods. 

Thermo Fisher Scientific India Pvt. Ltd. v DCIT [2026] GCtR 53 (ITAT, Mumbai)

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