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The HC set aside the ITAT order concerning the TP adjustment and comparable selection, finding that ITAT failed to provide adequate reasons for including certain entities such as Comviva Technologies Ltd. and Cybercom Datamatics Information Solutions Ltd. The court noted that ITAT did not properly address the Assessee's contentions regarding the lack of functional comparability and absence of analysis by the TPO or DRP. Specifically, ITAT erred in accepting comparables without discussing the functional dissimilarities highlighted by the Assessee. Consequently, the HC remanded the matter to ITAT for reconsideration and directed it to pass a reasoned order on the Assessee's objections, ensuring proper evaluation of the comparability analysis in accordance with transfer pricing principles.
The HC set aside the ITAT order concerning the TP adjustment and comparable selection, finding that ITAT failed to provide adequate reasons for including certain entities such as Comviva Technologies Ltd. and Cybercom Datamatics Information Solutions Ltd. The court noted that ITAT did not properly address the Assessee's contentions regarding the lack of functional comparability and absence of analysis by the TPO or DRP. Specifically, ITAT erred in accepting comparables without discussing the functional dissimilarities highlighted by the Assessee. Consequently, the HC remanded the matter to ITAT for reconsideration and directed it to pass a reasoned order on the Assessee's objections, ensuring proper evaluation of the comparability analysis in accordance with transfer pricing principles.
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