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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

DCIT 8(3)(2), Mumbai vs. M/S Vodafone Idea Limited (Earlier Known As Vodafone India Limited Which Now Stands Merged With Idea Cellular Limited (Icl) and Consequently Known As Vodafone Idea Limited), Mumbai

ITA 1919/MUM/2016[2011-12]Status: DisposedITAT Mumbai17 May 2024AY 2011-12
For Appellant: Shri P.J. PardiwalaFor Respondent: Shri T. Sankar
Section 115JSection 143(3)Section 144C(13)Section 144C(5)Section 14ASection 234DSection 271(1)(c)Section 36(1)(iii)Section 37Section 40

IN THE INCOME TAX APPELLATE TRIBUNAL "I" BENCH, MUMBAI SHRI S RIFAUR RAHMAN, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER

Culver Max Entertainment Private Lmited ( Formerly Sony Pictures Networks India Pvt. Ltd. (Successor of Taj Television India Pvt. Ltd.), Mumbai vs. ACIT, Circle- 16 (1), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 7210/MUM/2019[2011-12]Status: DisposedITAT Mumbai26 Apr 2024AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm M/S Sony Pictures Networks Asst. Commissioner Of India Private Limited Income-Tax, (Successor Of Taj Television Circle 16(1) India Private Limited) Aaykar Bhavan, Vs. Interface 7, 4Th Floor, Off Malad Room No. 467, Link Road, Malad (W), M.K. Marg, Mumbai-400 020 Mumbai-400 064 (Appellant) (Respondent) Pan No. Aabct5103D Assessee By : Shri Fenil Bhatt, Ar Revenue By : Shri B.K. Bagchi, Dr Date Of Hearing: 01.02.2024 Date Of Pronouncement : 26.04.2024

For Appellant: Shri Fenil Bhatt, ARFor Respondent: Shri B.K. Bagchi, DR
Section 143(3)Section 144C

claim of the assessee that between these two halfs of the previous year there is no change in the Functions Assets and Risks Analysis (FAR) analysis. This is also reiterated in its written submission. Thus, undisputedly, the FAR for both the periods is same but Revenue sharing of the assessee ... Therefore the treatment of the assessee that both the transaction should be considered as a single transaction as there is no change in the far analysis is devoid of any merit. This is so because if there is no M/s Sony Pictures Networks India Pvt. Ltd; A.Y. 11-12 change

Idemia Syscom India Private Limited, Noida vs. CIT(Tp), Delhi-2, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 647/DEL/2024[2020-21]Status: DisposedITAT Delhi28 Mar 2024AY 2020-21

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

For Appellant: Shri M.S. Syali, Sr. AdvFor Respondent: Shri Rajesh Kumar, CIT- DR
Section 263Section 92C

accepted to be at arm’s length without conducting necessary enquiry/verifications of the facts. Strong emphasis was placed on the fact that in the FAR analysis done in Transfer Pricing Study Report, the assessee has characterized itself as a manufacturer of SIM Card and Smart Card, bearing routine risk. However ... revenue in the books may lead to reduction of tax liability of the assessee and profit shifting out of India. 3.5 In the FAR analysis done in the TP study report, assessee has characterized itself as a manufacturer of SIM cards and Smart cards bearing routine risk. However

M/S. Spectris Technologies (P) Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 1818/DEL/2013[2007-08]Status: DisposedITAT Delhi07 Mar 2024AY 2007-08

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

For Appellant: Shri Tarandeep Singh, AdvFor Respondent: Shri Manish Kumar Dabas, Sr. DR

counsel for the assessee vehemently stated that the TPO/CIT(A)/Assessing Officer has misunderstood the facts in true perspective while doing FAR analysis of the assessee. 8. The quarrel revolves around the following observations of the TPO confirmed by the ld. CIT(A): “5.2 The FAR analysis of the assessee ... carries out sales of spares parts on behalf of the AE. From the functions performed, assets utilized and risks assumed, FAR analysis of the assessee, it is .clear that the provision of AMC Services are inextricably linked to other functions with respect to purchase of equipment and provision of other

Avery Dennison (India) Private Limited, New Delhi vs. ACIT, Circle-1(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 538/DEL/2022[2013-14]Status: DisposedITAT Delhi04 Mar 2024AY 2013-14

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Ankit Sahani, Adv. &For Respondent: Sh. Rajesh Kumar, CIT-DR
Section 143(3)

respectfully submitted that the documents/evidences brought before the Hon'ble tribunal clearly fail to show any rendering of services. No FAR analysis, as mentioned by TPO is conducted with regard to functions performed by AE’s. Thus the AO has rightly made the adjustments because of clear cut failure

Zydus Lifesciences Limited (Formerly Known As Cadila Healthcare Ltd.), Ahmedabad vs. DCIT, Circle-1(1)(2), Ahmedabad

In the result, the appeal of the assessee is partly allowed in above terms

ITA 1884/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad23 Feb 2024AY 2015-16

Bench: Smt.Annapurna Gupta & Ms. Suchitra Raghunath Kambleassessment Year : 2015-16 Zydus Lifesciences Ltd. (Formerly Vs. The Dcit, Cir.1(1)(2) Known As Cadila Healthcare Ltd., Ahmedabad. 4Th Floor, D-Wing, Zydus Corporate Park, Scheme No.63, Survey No.536, Khoraj (Gandhinagar), Nr.Vaishnodvi Circle, Sg Highway, Ahmedabad Pan : Aaacc 6253 G (Applicant) (Responent) Assessee By : Shri Jigar Patel, Ar Revenue By : Shri Sudhendu Das, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 29/11/2023 घोषणा क" तारीख /Date Of Pronouncement: 23/02/2024 आदेश/O R D E R आदेश आदेश आदेश Per Annapurna Gupta

For Appellant: Shri Jigar Patel, ARFor Respondent: Shri Sudhendu Das, CIT-DR
Section 143(3)Section 144C(13)Section 92B

entrepreneur whereas the associate entity was only a distributor. The TPO and the DRP took a view that there was a contradiction in FAR analysis in the TP report and submissions made by the assessee, while justifying the ALP expenses reimbursed. It was noted that the FAR analysis ... behalf of the assessee for administrative convenience. The TPO as well as the DRP however took the view that there was contradiction in the FAR analysis in the transfer pricing report and the submissions made while justifying the reimbursement of expenses. This was also observed

Shree Cement Limited, Beawar vs. National Faceless Assessment Centre, Delhi

In the result, the appeal of the Revenue in ITA No

ITA 500/JPR/2023[215-16]Status: DisposedITAT Jaipur21 Feb 2024

Bench: or at the time of hearing of this appeal.

For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144BSection 144B(1)(xvi)Section 80Section 80I

however made modifications and revised the PSM to 64 % as against the PSM of 79.73 % adopted by the assessee on the basis of the FAR analysis adopted by the department in A. Y. 2013-14. TPO for the year under consideration carried out independent FAR analysis to arrive

Shree Cement Limited, Beawar vs. National Faceless Assessment Centre, Deputy Commissioner of Income Tax, Circle -2, Ajmer

ITA 498/JPR/2023[2018-19]Status: DisposedITAT Jaipur21 Feb 2024AY 2018-19
For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

however made modifications and revised the PSM to 64 % as against the PSM of 79.73 % adopted by the assessee on the basis of the FAR analysis adopted by the department in A. Y. 2013-14. TPO for the year under consideration carried out independent FAR analysis to arrive

Shree Cement Limited, Beawar vs. National Faceless Assessment Assessment Centre, Deputy Commissioner of Income Tax, Circle-2, Ajmer

ITA 497/JPR/2023[2017-18]Status: DisposedITAT Jaipur21 Feb 2024AY 2017-18
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

however made modifications and revised the PSM to 64 % as against the PSM of 79.73 % adopted by the assessee on the basis of the FAR analysis adopted by the department in A. Y. 2013-14. TPO for the year under consideration carried out independent FAR analysis to arrive

Shree Cement Limited, Beawar vs. National Faceless Assessment Centre, Deputy Commissionerof Income Tax, Circle -2, Ajmer

In the result, the appeal of the Revenue in ITA No

ITA 496/JPR/2023[2016-17]Status: DisposedITAT Jaipur21 Feb 2024AY 2016-17

Bench: or at the time of hearing of this appeal.

For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144BSection 144B(1)(xvi)Section 80Section 80I

however made modifications and revised the PSM to 64 % as against the PSM of 79.73 % adopted by the assessee on the basis of the FAR analysis adopted by the department in A. Y. 2013-14. TPO for the year under consideration carried out independent FAR analysis to arrive

Assisstant Commissioner of Income Tax, Ajmer vs. Shree Cement Ltd, Beawar

ITA 490/JPR/2023[2016-17]Status: DisposedITAT Jaipur21 Feb 2024AY 2016-17
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

however made modifications and revised the PSM to 64 % as against the PSM of 79.73 % adopted by the assessee on the basis of the FAR analysis adopted by the department in A. Y. 2013-14. TPO for the year under consideration carried out independent FAR analysis to arrive

Assisstant Commissioner of Income Tax, Ajmer vs. Shree Cement Ltd, Beawar

ITA 489/JPR/2023[2015-16]Status: DisposedITAT Jaipur21 Feb 2024AY 2015-16
For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

however made modifications and revised the PSM to 64 % as against the PSM of 79.73 % adopted by the assessee on the basis of the FAR analysis adopted by the department in A. Y. 2013-14. TPO for the year under consideration carried out independent FAR analysis to arrive

DCIT, Circle-6(1), Kolkata vs. M/S. Ifb Agro Industries Ltd., Kolkata

In the result, both the appeals filed by the revenue in ITA No

ITA 491/KOL/2019[2014-15]Status: DisposedITAT Kolkata09 Feb 2024AY 2014-15

Bench: Dr. Manish Borad&Shri Anikesh Banerjee]

Section 143(3)Section 14ASection 250Section 80ISection 92C

facts on record that the CPP was indeed distributing and supplying power to the non-eligible undertaking through transmission lines and hence the FAR analysis performed by the Ld. AO/TPO was unjustified. It is also observed that the Ld. TPO/AO erred in considering different forms of power units such

DCIT, Circle-6(1), Kolkata vs. M/S. Ifb Agro Industries Ltd., Kolkata

In the result, both the appeals filed by the revenue in ITA No

ITA 490/KOL/2019[2013-14]Status: DisposedITAT Kolkata09 Feb 2024AY 2013-14

Bench: Dr. Manish Borad&Shri Anikesh Banerjee]

Section 143(3)Section 14ASection 250Section 80ISection 92C

facts on record that the CPP was indeed distributing and supplying power to the non-eligible undertaking through transmission lines and hence the FAR analysis performed by the Ld. AO/TPO was unjustified. It is also observed that the Ld. TPO/AO erred in considering different forms of power units such

Adobe Systems Software Ireland Limited, Dublin (Ireland) vs. ACIT Circle 1(1)(1), International Taxation, New Delhi

Accordingly, the additions made by the Ld. AO in the impugned case deserve to be deleted on the merit for the year under consideration. Thus, the grounds raised are allowed and appeal of asseessee ...

ITA 3672/DEL/2023[AY 2021-22]Status: DisposedITAT Delhi09 Feb 2024

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmastay Application No.52/Del/2024 (Ita No.3672/Del/2023) Assessment Year: 2021-22 & Assessment Year: 2021-22 Adobe Systems Software Ireland Vs Acit, Limited, Circle-1(1)(1), Dublin (Ireland), International Taxation, 4-6, Riverwalk, Citywest Business New Delhi. Campus, Saggart, Dublin 24, Ireland. Pan: Aahca7203M (Applicant) (Respondent) Assessee By : Shri Ravi Sharma, Advocate & Ms Shruti Khimta, Ar Revenue By : Shri Om Parkash, Sr. Dr Date Of Hearing : 09.02.2024 Date Of Pronouncement : 09.02.2024 Order Per Anubhav Sharma, Jm: Heard & Perused The Records. 2. The Stay Application In Hand Has Been Filed For The Stay Of Demand In Regard To Ay 2021-22 And, During The Course Of Argument, It Was Submitted By Ita No.52/Del/2024

For Appellant: Shri Ravi Sharma, Advocate &For Respondent: Shri Om Parkash, Sr. DR
Section 139(1)

well understanding this proposition, the Revenue itself urged that without prejudice to the above, the judicial decision of the attribution of profit by applying FAR analysis has not been accepted by the Indian Government and the profit has to be determined by apply of provisions of DTAA r.w.s

Fulford (India) Ltd, Mumbai vs. DCIT Cir 2(1), Mumbai

In the result, appeal of assessee is partly allowed for statistical purpose

ITA 338/MUM/2014[2009-10]Status: DisposedITAT Mumbai06 Feb 2024AY 2009-10

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआ.अ.सं.338/मुं/2014(िन.व.2009-10) Fulford (India) Limited, Platina Building, 8Th Floor, C-59, G-Block, Bandra Kurla Complex, Bandra (East), Mumbai – 400 098 Pan: Aaacf-1795-L ...... अपीलाथ"/Appellant बनाम Vs. Dy.Commissioner Of Income Tax, Circle 2(1), Room No.561, 5Th Floor, Aaykar Bhavan, M.K.Road, Mumbai – 400 020. ..... "ितवादी/Respondent Assessee By : Shri P.J. Pardiwala, Sr. Advocate With Shri Madhur Agrawal, Advocate Revenue By : Dr. Yogesh Kamat, Cit-Dr & Shri Ujjwal Kumar Chavan, Sr.Ar सुनवाई क" ितिथ/ Date Of Hearing : 10/11/2023 घोषणा क" ितिथ/ Date Of Pronouncement : 06/02/2024 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 13/12/2013 Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 [In Short ‘The Act’], For The Assessment Year 2009-10. 2. The Facts Of The Case In Brief Are: The Assessee/Appellant Is Engaged In The Business Of Manufacturing & Distribution Of Pharmaceutical Products In 2 India. The Assessee Is A Subsidiary Of Schering-Plough Corporation, Usa. During The Period Relevant To The Assessment Year Under Appeal, The Assessee Entered Into Various International Transactions With Its Associated Enterprise(Ae). During The Course Of Assessment Proceedings The Transfer Pricing Officer (Tpo) Made Adjustment In Respect Of Following International Transactions: Sl.No. Description Of International Transaction Adjustment Made By Tpo (Amount In Rs.) 1. Import Of Active Pharmaceutical 4,81,96,325 Ingredients (Apis) 2 Import Of Finished Drug Formulations (Fdf) 15,75,53,000 Total 20,57,49,325

For Appellant: Shri P.J. Pardiwala, Sr. Advocate with Shri Madhur Agrawal, AdvocateFor Respondent: Dr. Yogesh Kamat, CIT-DR &
Section 143(3)

factory price plus 110%, which is the premium to be paid as per DPCO norms. There is hardly any substantive difference in FAR analysis because of the new agreement, except that in earlier agreement there was clear mention that the assessee is a ‘distributor’ which has now been changed

Yokogawa India Limited, Bangalore vs. Deputy Commissioner of Income Tax Large Taxpayers Unit, Bangalore

In the result, the appeal by the assessee is partly allowed

ITA 2088/BANG/2017[2013-14]Status: DisposedITAT Bangalore01 Feb 2024AY 2013-14

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 14A

therefore to maintain parity, we reject the argument of the ld. DR that Govt. company cannot be considered as a comparable, if it passes FAR analysis. We further observe that the TPO has observed this company is a persistent loss making company. However, as per the computation submitted ... assessee company and the ld. AR had also calculated PLI in which the company has profit in one year as observed above. FAR analysis of comparable has to be considered for each year separately irrespective of other years. Accordingly we remit this issue to the ld. TPO/AO for de novo

Marvell India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-4(1)(2), Bangalore

In the result, appeal of the assessee is partly allowed

ITA 343/BANG/2021[2016-17]Status: DisposedITAT Bangalore10 Jan 2024AY 2016-17

Bench: Shri George George K & Shri Chandra Poojariit(Tp)A No.343/Bang/2021 Assessment Year : 2016-17 M/S. Marvell India Pvt. Ltd., Vs. Acit, Tower D, 10Th & 11Th Floors, Circle – 4(1)(2), Global Technoloyg Park, Marathahalli – Bengaluru. Sarjapur Outer Ring Road, Bellandur, Bengaluru – 560 103. Pan : Aaecm 5559 R Appellant Respondent Assessee By : Shri. Mukesh Butani, Advocate Revenue By : Shri. G. Manoj Kumar, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 10.01.2024 Date Of Pronouncement : 10.01.2024 O R D E R Per George George K:

For Appellant: Shri. Mukesh Butani, AdvocateFor Respondent: Shri. G. Manoj Kumar, CIT(DR)(ITAT), Bengaluru
Section 143(2)Section 143(3)Section 144CSection 92C

wherein it was held that high turnover ipso facto does not lead to the conclusion that a company which is otherwise comparable on FAR analysis can be excluded and that the effect of such high turnover on the margin should be seen. The DRP therefore held that a company which

Adobe Systems Software Ireland Ltd, Ireland vs. ACIT, Circle 1(1)(1), International Taxation, New Delhi

Appeal is allowed in terms indicate above

ITA 804/DEL/2023[2016-17]Status: DisposedITAT Delhi22 Dec 2023AY 2016-17

Bench: Shri Shamim Yahya & Shri Kul Bharat[Assessment Year : 2016-17] Adobe Systems Software Ireland Vs Acit, Ltd., 406, Riverwalk, Citywest Circle-1(1)(1), Business Campus, Saggart, International Dublin 24, Ireland Taxation, Pan-Aahca7203M New Delhi. Appellant Respondent Appellant By Shri Ravi Sharma, Adv. & Ms. Shruti Khimta, Ar Respondent By Shri Vizay B.Vasanta, Cit Dr Date Of Hearing 12.12.2023 Date Of Pronouncement 22.12.2023 Order Per Kul Bharat, Jm : The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By Ld.Acit, Circle-International Taxation 1(1)(1), Delhi Dated 24.01.2023 For The Assessment Year 2016-17. 2. The Assessee Has Raised Following Grounds Of Appeal:-

that if the international transactions between the parent entity (HO) and associated entity (AE) stand accepted at an Arm's length based on FAR analysis, in that case, the question of appropriation of profit to DAPE does not arise. That his argument sans the concept of separate entity approach ... well understanding this proposition, the Revenue itself urged that without prejudice to the above, the judicial decision of the attribution of profit by applying FAR analysis has not been accepted by the Indian Government and the profit has to be determined by apply of provisions of DTAA r.w.s.10A

Arkha Solar Power Private Limited, Rajahmundary vs. DCIT-1, Kakinada

In the result, appeal of the assessee is allowed

ITA 92/VIZ/2022[2017-2018]Status: DisposedITAT Visakhapatnam22 Dec 2023AY 2017-2018

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble(Through Hybrid Hearing) आयकरअपीलसं./ I.T.A. No.92/Viz/2022 ("नधा"रणवष"/ Assessment Year : 2017-18) Arkha Solar Power Private Vs. Deputy Commissioner Of Limited, Income Tax-1, Elakolanu Village, 4Th Floor, Sri Deepthi Towers, Rangampeta, Rajahmundry, Main Road, Kakinada, Andhra Pradesh – 533294. Andhra Pradesh-533001. Pan: Aalca 4293K (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ"क"ओरसे/ Assessee By : Ms. Karishma R. Phatarphekar ""याथ"क"ओरसे/ Revenue By : Dr. Satyasai Rath, Cit-Dr

For Appellant: Ms. Karishma R. PhatarphekarFor Respondent: Dr. Satyasai Rath, CIT-DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 92C(1)

having valid coupon 961 rate (after excluding zero coupon rate) 5 Instruments pertaining to energy 64 sector 6 Debt instruments as comparables 8 after FAR analysis and excluding Govt / PSU issued instruments The Ld. TPO then aggregated the list of comparables from BSE, NSDL and CDSL as follows: S.No Company