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The ITAT partially allowed the appeal by remanding the transfer pricing issue to the AO/TPO for fresh selection of comparables after applying the RPT filter with a 25% threshold, excluding functionally dissimilar entities such as M/s Angel Financial Advisors Pvt. Ltd. The AO/TPO was directed to rework the comparable analysis including companies suggested by the assessee and to apply correct margins as per the DRP's direction. Grounds 2 to 2.11 were partly allowed for statistical purposes. Regarding interest under sections 234B and 234C, the AO/TPO was directed to compute interest on the final income determined, disregarding additional income declared in the modified return filed under the APA framework. The decision aligns with prevailing judicial precedents and emphasizes adherence to correct comparability criteria and margin computations in transfer pricing assessments.
The ITAT partially allowed the appeal by remanding the transfer pricing issue to the AO/TPO for fresh selection of comparables after applying the RPT filter with a 25% threshold, excluding functionally dissimilar entities such as M/s Angel Financial Advisors Pvt. Ltd. The AO/TPO was directed to rework the comparable analysis including companies suggested by the assessee and to apply correct margins as per the DRP's direction. Grounds 2 to 2.11 were partly allowed for statistical purposes. Regarding interest under sections 234B and 234C, the AO/TPO was directed to compute interest on the final income determined, disregarding additional income declared in the modified return filed under the APA framework. The decision aligns with prevailing judicial precedents and emphasizes adherence to correct comparability criteria and margin computations in transfer pricing assessments.
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