TP to be on accurate computation on RP transaction

The Hyderabad Bench of the Income Tax Appellate Tribunal has emphasized that comparable selection in transfer pricing matters must be based on accurate computation of Related Party Transactions (RPT) and a proper appreciation of factual data available in the records. 

The Tribunal found that certain companies were excluded from the final set of comparables on the basis of erroneous assumptions regarding the availability and computation of RPT details. 

Accordingly, it remanded the issues relating to the comparability of I Services India Private Limited and Cheers Interactive India Private Limited to the Transfer Pricing Officer for fresh verification and recomputation. 

The Tribunal also directed verification of an alleged double disallowance of interest on TDS, thereby granting the assessee partial relief.