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“FAR analysis”

Transfer PricingSection 92CSection 92C371 judgments

The decision most relied on for FAR analysis is UCB India (P) Limited v. ACIT (121 ITD 131), cited in 70 judgments on BharatTax.

Leading authorities on FAR analysis

UCB India (P) Limited v. ACIT
121 ITD 131 · 2009 · ITAT
70
citing judgments

For transfer pricing purposes, distinct international transactions, such as royalty payments and manufacturing, should be benchmarked separately rather than aggregated. The selection of comparables must be based on a thorough Functions, Assets, and Risks (FAR) analysis, and loss-making entities are not automatically excluded if they satisfy other comparability criteria.

Genesis Integrating Systems India Pvt Ltd. v. DCIT
53 SOT 159 · 2012 · ITAT
57
citing judgments

Companies with significantly different turnovers (e.g., one above Rs. 200 crores and another below) cannot be considered comparable in transfer pricing analysis. Turnover is a relevant factor in assessing comparability.

DCIT v. Electronics for Imaging India P. Ltd.
70 Taxmann.com 299 · 2016 · ITAT
51
citing judgments

For transfer pricing purposes, companies engaged in functionally different activities, such as payroll processing versus software development, are not comparable and must be excluded from the list of comparables.

Dy. DIT (IT) v. Set Satellite (Singapore) Pte. Ltd.
106 ITD 175 · 2007 · ITAT
50
citing judgments

For computing profits of a dependent agency permanent establishment (DAPE), the 'two taxpayer approach' is upheld. A hypothetical DAPE is visualized based on the General Enterprise's functions performed, assets used, and risks assumed, given the absence of a physical establishment.

Commissioner of Income Tax v. Merck Ltd.
389 ITR 70 · 2016 · High Court
48
citing judgments

Ad-hoc transfer pricing adjustments are not justified if the Transfer Pricing Officer fails to apply one of the prescribed methods under Section 92C. The arm's length nature of international transactions, including intra-group services and management fees, should be determined through a detailed FAR analysis and benchmarking study.

Chryscapital Investment Advisors India Pvt.Ltd. v. DCIT
82 Taxmann.com 167 · 2017 · High Court
38
citing judgments

A company that is otherwise comparable on a functional and comparability analysis (FAR analysis) cannot be excluded solely based on high turnover; the effect of such high turnover on the margin must be considered.

SwissRe Global Business Solutions India (P.) Ltd. v. Dy. CIT
116 Taxmann.com 716 · 2020 · Reported
13
citing judgments

Working capital adjustment is an accepted adjustment provided for better comparability in transfer pricing. The Tribunal has held that working capital adjustment is necessary for better comparability.

Judgments citing FAR analysis

Srf Limited, Delhi vs. Assistant / Deputy Commissioner of Income Tax, Circle 10(1), New Delhi, Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 5618/DEL/2024[2021-22]Status: DisposedITAT Delhi12 Dec 2025AY 2021-22
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

most appropriate method being ‘CUP Method’ which is a direct price based method and instead applying the ‘TNMM’ in an arbitrary manner, not providing FAR analysis and search process to assessee and resultantly taking companies which are product wise and functionally incomparable to the assessee’s TTBK unit. 34.0 Without

Swatch Group (India) Retail Private Limited, Delhi vs. The Deputy Commissioner of Income Tax, Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 4281/DEL/2024[2020-21]Status: DisposedITAT Delhi12 Dec 2025AY 2020-21

Bench: Shri S.Rifaur Rahman & Ms. Madhumita Royswatch Group (India) Retail Private Ltd., Vs. Dcit, Circle 22(2), 4Th Floor, Rectangle 1, Plot No.D4, Delhi. Saket District Centre, Saket, New Delhi – 110 017. (Pan : Aavcs7960H) (Appellant) (Respondent) Assessee By : Shri Ravi Sharma, Advocate Ms. Shruti Khimta, Ar Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 16.09.2025 Date Of Order : 12.12.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 26.07.2024 Passed By The Assessment Unit, Income Tax Department Under Section 143(3) Read With Section 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2020-21 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :-

For Appellant: Shri Ravi Sharma, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 92C(3)Section 92D

sale and purchases alongwith the details of the parties involved (Paper Book Pages 33 & 37); d. Transfer Pricing Report providing details of transaction, FAR analysis, approach of the Appellant while computing arm's length price and segmental information on page 77 of the Paper Book; e. Submissions dated September

Srf Limited, Delhi vs. ACIT, Circle-10(1), Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 1449/DEL/2022[2018-19]Status: DisposedITAT Delhi12 Dec 2025AY 2018-19
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

most appropriate method being ‘CUP Method’ which is a direct price based method and instead applying the ‘TNMM’ in an arbitrary manner, not providing FAR analysis and search process to assessee and resultantly taking companies which are product wise and functionally incomparable to the assessee’s TTBK unit. 34.0 Without

Srf Limited, New Delhi vs. ACIT, Circle-10(1), Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 1448/DEL/2022[2017-18]Status: DisposedITAT Delhi12 Dec 2025AY 2017-18
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

most appropriate method being ‘CUP Method’ which is a direct price based method and instead applying the ‘TNMM’ in an arbitrary manner, not providing FAR analysis and search process to assessee and resultantly taking companies which are product wise and functionally incomparable to the assessee’s TTBK unit. 34.0 Without

Assisstant Commissioner of Income Tax, Mumbai vs. Asr Multimetals Private Limited, Mumbai

In the result, appeals for all the assessment years filed by the revenue stand dismissed

ITA 4935/MUM/2024[2017]Status: DisposedITAT Mumbai24 Nov 2025

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 133(6)Section 80I

using the rates at which state power distribution companies had purchased power from the generating companies which is appropriate comparable as per FAR analysis. 2. Whether on the fact and circumstances of the case and in law, the Ld. CIT(A) is justified in allowing the assessee for selecting power ... power generating company as tested party for benchmarking of Specified Domestic Transactions of inter unit transfer of power ignoring the comparability factor and FAR analysis." 3. The Appellant prays that the order of the CIT(A) on the above grounds he set aside and that of the Assessing Officer

Assistant Commissioner of Income Tax, Mumbai vs. Asr Multimetals Private Limited, Mumbai

In the result, appeals for all the assessment years filed by the revenue stand dismissed

ITA 4933/MUM/2024[2018-19]Status: DisposedITAT Mumbai24 Nov 2025AY 2018-19

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 133(6)Section 80I

using the rates at which state power distribution companies had purchased power from the generating companies which is appropriate comparable as per FAR analysis. 2. Whether on the fact and circumstances of the case and in law, the Ld. CIT(A) is justified in allowing the assessee for selecting power ... power generating company as tested party for benchmarking of Specified Domestic Transactions of inter unit transfer of power ignoring the comparability factor and FAR analysis." 3. The Appellant prays that the order of the CIT(A) on the above grounds he set aside and that of the Assessing Officer

Assistant Commissioner of Income Tax, Mumbai vs. Asr Multimetals Private Limited, Mumbai

In the result, appeals for all the assessment years filed by the revenue stand dismissed

ITA 4931/MUM/2024[2020-21]Status: DisposedITAT Mumbai24 Nov 2025AY 2020-21

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 133(6)Section 80I

using the rates at which state power distribution companies had purchased power from the generating companies which is appropriate comparable as per FAR analysis. 2. Whether on the fact and circumstances of the case and in law, the Ld. CIT(A) is justified in allowing the assessee for selecting power ... power generating company as tested party for benchmarking of Specified Domestic Transactions of inter unit transfer of power ignoring the comparability factor and FAR analysis." 3. The Appellant prays that the order of the CIT(A) on the above grounds he set aside and that of the Assessing Officer

Lintas India Private Limited, Mumbai vs. DCIT, Circle 16(1), Mumbai

The appeal of the assessee is partly allowed for statistical purposes

ITA 5889/MUM/2024[2021-22]Status: DisposedITAT Mumbai19 Nov 2025AY 2021-22

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2021-22 M/S. Lintas India Private Assessment Unit, Limited, Income Tax Department Or A Wing, 16Th Floor, Deputy Commissioner Of Parinee Crescenzo, Income Tax, Bandra-Kurla Complex, Circle 16(1), Bandra (East), 1) National Faceless Mumbai – 400 051 Assessment Centre (Nafac), Vs. Pan: Aaacl0124F Delhi 2)Aayakar Bhawan, Maharshi Karve Road, New Marine Lines, Churchgate, Mumbai – 400020 (Appellant) (Respondent) Present For: Assessee By : Shri Ajit Jain, Ld. A.R. Shri Karnik Kansara, Ld. A.R Ms. Neha Rai, Ld. A.R. Ms. Sakshi Chimanani, Ld. A.R. Revenue By : Shri Kiran Unavekar, Ld. Sr. D.R. Date Of Hearing : 22.08.2025 Date Of Pronouncement : 19.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 15.05.2023, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax (Dispute Resolution Panel-1) (In Short Ld. Commissioner) U/S 144C(5) Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2021-22. 2 M/S. Lintas India Private Limited

For Appellant: Shri Ajit Jain, Ld. A.RFor Respondent: Shri Kiran Unavekar, Ld. Sr. D.R
Section 144Section 144CSection 144C(5)Section 92C

certain comparables of the world by using TNMM method, however the deficiencies in such selection of comparables and 8 M/s. Lintas India Private Limited FAR Analysis has been rightly highlighted by the TPO as discussed above. In fact, the assessee has totally ignored the Sixth method in its TPSR which ... various documentation for GSA services which are on the same lines as of AY 2018-19, such as copy of agreements, Benchmarking in analysis, FAR analysis, cost allocation working, independent auditor’s certificate for allocation of GSA, post benefits derived from GSA services, chart-summary of GSA services

Shell India Markets Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(4), Mumbai

ITA 4828/MUM/2024[2020-21]Status: DisposedITAT Mumbai19 Nov 2025AY 2020-21

Bench: SHRI AMIT SHUKLA, JUDICIAL MEMBER\n&\nMS. PADMAVATHY S (Accountant Member)

Section 143(3)Section 144BSection 144C(1)Section 144C(13)Section 144C(5)Section 270ASection 40Section 92C

crore is an objective filter designed to weed out start-up or defunct entities. Once that threshold is applied, functional comparability and FAR analysis should guide the inclusion or exclusion of comparables. • In contrast, a mechanical 1/10 to 10 times turnover band is inherently subjective and arbitrary; there ... completion of the search process with the object of excluding comparables which was otherwise found to be functionally comparables after the Functions Assets Risks (FAR) Analysis. After taking into facts and circumstances of the present case, we are of the view that the application of the second lower turnover filter

Aditya Birla Nuvo Ltd (Since Amalgamated With Grasim Industries Limited), Mumbai vs. DCIT CC-1(4) Earlier With ACIT(Ltu) 1, Mumbai

In the result, theappeals filed by the assessee and revenue are partly

ITA 563/MUM/2018[2013-14]Status: DisposedITAT Mumbai17 Nov 2025AY 2013-14

Bench: The Hon’Bleunder Section 255(4) Of The Act. The Points Of Difference Were Thereafter Referred To The Hon’Blefor Resolution. The Hon’Blehas Now Rendered His Detailed Opinion & The Appeals Have Been Placed Before Us To Pass The Consequential

Section 255(4)Section 80

distribution licensee to the end consumer. He submitted, even Rule 10B(2)(b) which provides for determination of ALP and difference in the FAR analysis between a power generator and distribution licensee has to be accounted for. He submitted, while learned Accountant Member has taken note of such difference ... FAR analysis, learned Judicial Member has not disputed it. He submitted, decisions cited by learned counsel for the assessee are sub silentio on this aspect. He submitted, since the decisions cited on behalf of the assessee have not taken note of Section 80A(6) of the Act, they cannot

Applexus Technologies Private Limited, Trivandrum vs. DCIT, Kottayam

ITA 955/COCH/2024[2021-2022]Status: DisposedITAT Cochin13 Nov 2025AY 2021-2022
For Appellant: Shri Reuben JosephFor Respondent: Shri Sanjit Kumar Das
Section 143(3)Section 144BSection 144CSection 144C(1)Section 144C(5)

filters for selection of comparable and had not considered current year data for comparability analysis. Proper comparability can be achieved only after making proper FAR analysis of the tested party and based on this analysis, significant economic functions are identified and thereafter relevant filters are adopted based on significant economic

Highradius Technologies Private Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Circle -2(1), Hyderabad

ITA 436/HYD/2024[2020-21]Status: HeardITAT Hyderabad12 Nov 2025AY 2020-21

Bench: Us:

Section 143(1)Section 143(3)Section 144B

comparables in question, we deem it apposite to cull out the functional, asset, and risk (FAR) profile of the assessee company before us. The FAR analysis of the assessee company as per its TP study report and other documents, reveals as under:  Functions: The assessee company performs software development, testing ... employee-related or delivery-related risks, while the market, credit, and product risks are borne entirely by its AE. Accordingly, based on the FAR analysis of the assessee company, it can safely be characterized as a low-risk captive software development service provider. 18. We shall now deal with

Ecoenergy Insights Ltd ( Formerly Known As Chubb Alba Control Systems P.Ltd), New Delhi vs. DCIT, Circle-4(2), New Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 2321/DEL/2022[2018-19]Status: DisposedITAT Delhi10 Nov 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaecoenergy Insights Ltd., Vs. Dcit, (Formerly Known As Chubb Alba Control Circle 4 (2), Systems P. Ltd.), New Delhi. Ground Floor, 18, Netaji Subhash Marg, Daryaganj, New Delhi – 110 002. (Pan :Aaaca0031C) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Shri Parth, Advocate Shri Pratik Rath, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 12.08.2025 Date Of Order : 10.11.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 25.07.2022Passed By The Assessment Unit, Income Tax Department Under Section 147 Read With Section 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Ay 2018-19 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(2)Section 144C(13)Section 144C(5)Section 147Section 92C

rejected the complete TP study submitted by the assessee. In our considered view, the TP study has to be completed on the basis of FAR analysis and there seems to be certain difference of opinion on the FAR itself between both parties and there is allegation from the assessee also ... redo the assessment of TP adjustment after proper analysis of FAR and redo the ALP afresh by selecting proper comparables as per the FAR analysis. It is needless to say that assessee may be given proper opportunity of being heard. Accordingly, these grounds raised by the assessee are allowed

Dgs Technical Services Private Limited, Hyderabad vs. DCIT., Circle-8(1), Hyderabad

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 1095/HYD/2024[2021-22]Status: DisposedITAT Hyderabad31 Oct 2025AY 2021-22

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 143(3)Section 144C(5)Section 92C

were not available in the database/universe considered by the Ld. TPO for benchmarking analysis In other words, the Ld. TPO has not examined the FAR analysis of the assessee company with the comparable companies selected by the assessee before rejecting the TP documentation submitted by the assessee company. Further, going ... NPCC Engineering Pvt. Ltd., Energy Infratech Pvt. Ltd., and AXIS CADESS Technology Ltd., in the final set of comparable upon verification of the relevant FAR analysis and filters applied for selection of comparable. Since the FAR analysis of the above three companies are similar to that of the assessee company

Bundy India Limited, Vadodara vs. The Dy. CIT., Circle-1(1), Baroda

In the result, Ground Number 6 of the assessee’s appeal is allowed for statistical purposes

ITA 1403/AHD/2016[2009-10]Status: DisposedITAT Ahmedabad30 Oct 2025AY 2009-10

Bench: Annapurna Gupta & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.1403/Ahd/2016 िनधा"रण वष" /Assessment Year : 2009-10 Bundy India Limited The Dy.Cit बनाम/ Plot No.2, Circle-1(1) V/S. Gidc Industrial Estate, Baroda Makarpura Vadodaria - 390 010 "थायी लेखा सं./Pan: Aaacb 3039 M (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri S.N. Soparkar, Sr. Advocate Revenue By : Shree Veerbadram Vislavath, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 31/07/2025 घोषणा की तारीख /Date Of Pronouncement: 30/10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm:

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shree Veerbadram Vislavath, Sr.DR
Section 133(6)Section 250Section 92CSection 92C(1)Section 92C(3)

that case was a miniscule 4% whereas such transactions in this case is substantial 58.48%. Further, this issue can be decided after undertaking FAR analysis of non-UK transactions in order to find out whether there is any distinction in the factors influencing the price Bundy India Ltd. vs. DCIT ... case of Dell International Services India (Pvt.) Ltd. Vs. DCIT (73 taxmann.com 24), wherein it was held that if after taking a FAR analysis of non-US transactions, it is found that factors influencing the price were similar between US and non-US AE transactions, same price fixed under

Dy. Commississioner of Income Tax, Dehradun vs. Weatherford Oil Tools Me Limited, Dehradun

In the result, Appeals of the Revenue’s are dismissed

ITA 168/DDN/2024[2016-17]Status: DisposedITAT Dehradun28 Oct 2025AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 448Section 44BSection 9(1)(vi)Section 9(1)(vii)

margin less than 1%. Accordingly, we have no hesitation to hold that the comparables chosen by the assessee duly fulfilled the comparability test of FAR analysis and in view of the decision of the Special Bench of Chandigarh Tribunal in the case of M/s Quark Systems

Dy. Commississioner of Income Tax, Dehradun vs. Weatherford Oil Tools Me Limited, Mumbai

In the result, Appeals of the Revenue’s are dismissed

ITA 167/DDN/2024[2021-22]Status: DisposedITAT Dehradun28 Oct 2025AY 2021-22

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 448Section 44BSection 9(1)(vi)Section 9(1)(vii)

margin less than 1%. Accordingly, we have no hesitation to hold that the comparables chosen by the assessee duly fulfilled the comparability test of FAR analysis and in view of the decision of the Special Bench of Chandigarh Tribunal in the case of M/s Quark Systems

Dy. Commississioner of Income Tax, Dehradun vs. Weatherford Oil Tools Me Limited, Mumbai

In the result, Appeals of the Revenue’s are dismissed

ITA 166/DDN/2024[2020-21]Status: DisposedITAT Dehradun28 Oct 2025AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 448Section 44BSection 9(1)(vi)Section 9(1)(vii)

margin less than 1%. Accordingly, we have no hesitation to hold that the comparables chosen by the assessee duly fulfilled the comparability test of FAR analysis and in view of the decision of the Special Bench of Chandigarh Tribunal in the case of M/s Quark Systems

Dy. Commississioner of Income Tax, Dehradun vs. Weatherford Oil Tools Me Limited, Mumbai

In the result, Appeals of the Revenue’s are dismissed

ITA 165/DDN/2024[2019-20]Status: DisposedITAT Dehradun28 Oct 2025AY 2019-20

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 448Section 44BSection 9(1)(vi)Section 9(1)(vii)

margin less than 1%. Accordingly, we have no hesitation to hold that the comparables chosen by the assessee duly fulfilled the comparability test of FAR analysis and in view of the decision of the Special Bench of Chandigarh Tribunal in the case of M/s Quark Systems

Dy. Commississioner of Income Tax, Dehradun vs. Weatherford Oil Tools Me Limited, Mumbai

In the result, Appeals of the Revenue's are dismissed

ITA 164/DDN/2024[2018-19]Status: DisposedITAT Dehradun28 Oct 2025AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalι.Τ.Α. No. 168/Ddn/2024 (A.Y 2016-17) Ι.Τ.Α. Νο. 163/Ddn/2024 (A.Y 2017-18) Ι.Τ.Α. Νο. 164/Ddn/2024 (A.Y 2018-19) Ι.Τ.Α. Νο. 165/Ddn/2024 (A.Y 2019-20) Ι.Τ.Α. No. 166/Ddn/2024 (A.Y 2020-21) Ι.Τ.Α. Νο. 167/Ddn/2024 (A.Y 2021-22) Dy. Commissioner Of Income Vs Weatherford Oil Tools M.E Tax, Aayakar Bhawan, 13-A, Subhash Road, Dehradun, Uttarakhand Limited. 6Th Floor, Vaman Centre, Makwana Road, J. B. Nagar, Mumbai, Maharashtra Pan: Aaacw1524G Appellant Respondent Assessee By Sh. Salil Kapoor, Adv, Sh. Amit Arora, Adv, Sh. Shivamyadav, Adv & Ms. Somya Singh, Adv Revenue By Sh. Mohan Lal Joshi, Sr. Dr Date Of Hearing 09/09/2025 Date Of Pronouncement 28/10/2025 Order Per Yogesh Kumar, U.S. Jm: The Captioned Appeals Are Filed By The Revenue Against The Orders Of Commissioner Of Income Tax (Appeals) Cit(A)-Noida, 2 ('Ld. Cit(A)' For Short), Delhi Dated 31/07/2024 For The Assessment Years2016-17, 2017-18, 2018-19, 2019-20, 2020-21 & 2021-22 Respectively. 2. All The Above Appeals Are Having Identical Issues To Be Decided, Therefore, The Captioned Appeals Filed By The Revenue Were Heard Together & Decided In This Common Order. 2

Section 44BSection 9(1)(vi)Section 9(1)(vii)

margin less than 1%. Accordingly, we have no hesitation to hold that the comparables chosen by the assessee duly fulfilling the comparability test of FAR analysis and in view of the decision of the Special Bench of Chandigarh Tribunal in the case of M/s Quark Systems