Similarity Of Functional Filters & Business Model Is Necessary For Including/ Excluding Comparable To Determine Arm's Length Price: Delhi HC

The Delhi High Court ruled that business similarity is essential when including or excluding comparable data for determining the arm's length price in transfer pricing cases. This decision ensures that companies must only consider truly comparable businesses when calculating pricing, maintaining fair taxation. The court's emphasis on correct benchmarking practices safeguards against arbitrary tax calculations, enhancing clarity in transfer pricing litigation.