Section 92C: Transfer pricing – Internal Comparables have a Priority

The Delhi Bench of ITAT has held that in course of determining Arm Length Price (ALP), preference should be given to internal uncontrolled comparable over external uncontrolled comparable, however, if nature of transaction with Associated Enterprise (AE) is different from that with non-AE or data in respect of two segments is either not workable or not reliable, then assistance from such internally comparable uncontrolled transactions should be avoided.