Selection of comparables is one of the most contentious issue between the taxpayer and the Transfer Pricing Officer (TPO) . This post is restricted to an issue whether the quotation from parties can be taken as comparabales for the purpose of the determination of arms length pricing (ALP) -whether for international transactions or specified domestic transactions . Biggest objection is that the quotation is not the actual data , so it should not be compared with actual data. But , that problem is no more..
