Comparable Used For First Time During ALP Determination Must Be Justified With Reasons: Punjab & Haryana High Court Deletes Arm's Length Price

The Punjab & Haryana High Court ruled that using a comparable for the first time in determining the Arm's Length Price (ALP) during transfer pricing assessments is justified if accompanied by valid reasons. The court deleted the ALP adjustment made by the tax authorities, upholding the taxpayer’s methodology.