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of <h1>ITAT directs exclusion of Madhya Pradesh Today Media from comparables under transfer pricing rules Section 92C</h1> <h3>IRDETO Technology India Private Limited Versus Assessment Unit, Income Tax Department, (Ld. AO).</h3> The ITAT Delhi allowed the assessee's appeal by directing the TPO to exclude Madhya Pradesh Today Media Company from the list of comparables in the ... TP adjustment - support service segment - Comparable selection - assessee only want to exclude Madhya Pradesh Today Media Company from the list of comparable - HELD THAT:- Perusal of the financials of Madhaya Pradesh Today Media Company would so that this company is engaged in business and selling of newspaper and not carrying on any business similar to the assessee. Nature of business conducted by the assessee altogether different, therefore, we conclude that this comparable is not functionally similar to the assessee. We direct the TPO to exclude this comparable from the list of comparable and then compute the Arm’s Length price once again and if the margin of the assessee are within the range then no adjustment is called for. Assessee appeal allowed. The Appellate Tribunal (ITAT Delhi) addressed the assessee's appeal against the Assessing Officer's order for AY 2021-22 concerning transfer pricing adjustments on support services rendered to its associated enterprise (AE). The key issue pertained to the Transfer Pricing Officer's (TPO) inclusion of Madhya Pradesh Today Media Company as a comparable for benchmarking the Arm's Length Price (ALP) of the support services segment amounting to Rs. 1,30,25,598/-. The assessee contended that this comparable was functionally dissimilar, being engaged in newspaper business unlike the assessee's contract development and support services. The Tribunal concurred, holding that Madhya Pradesh Today Media Company was 'not functionally similar' and directed the TPO to exclude it from the comparable set and recompute the ALP. If the recomputed margins fall within the prescribed range, 'no adjustment is called for.' Consequently, the appeal was allowed on this basis.
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