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The ITAT allowed the taxpayer's appeal, directing the exclusion of multiple comparables from transfer pricing analysis due to functional dissimilarity, related party transactions exceeding 25%, and lack of segmental revenue information. Upon exclusion of these entities, the remaining comparables' operating profit margins aligned with the assessee's declared margins, demonstrating arm's length pricing. The Tribunal instructed the Assessing Officer to recompute the Arm's Length Price by excluding specified companies, thereby deleting transfer pricing adjustments under Section 92CA(3) that were previously confirmed by the CIT(A).
The ITAT allowed the taxpayer's appeal, directing the exclusion of multiple comparables from transfer pricing analysis due to functional dissimilarity, related party transactions exceeding 25%, and lack of segmental revenue information. Upon exclusion of these entities, the remaining comparables' operating profit margins aligned with the assessee's declared margins, demonstrating arm's length pricing. The Tribunal instructed the Assessing Officer to recompute the Arm's Length Price by excluding specified companies, thereby deleting transfer pricing adjustments under Section 92CA(3) that were previously confirmed by the CIT(A).
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