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The ITAT set aside the transfer pricing adjustment made by the TPO, finding that the TPO failed to properly analyze the assessee's functions, risks, and operational profile, relying solely on the transfer pricing study without independent verification. The TPO erroneously compared the assessee, essentially a contract manufacturer without R&D activities, to large-scale enterprises with substantial independent research and higher turnovers. The matter was remanded to the TPO/AO for a fresh determination of arm's-length price, directing the assessee to submit comprehensive details on manufacturing processes, risks assumed, marketing, R&D activities, customer and supplier identification, and fresh comparability analysis reflecting the assessee's actual FAR profile. The TPO is to re-examine the issue and pass a reasoned order after affording the assessee a fair hearing. The appeal is allowed with these directions.
The ITAT set aside the transfer pricing adjustment made by the TPO, finding that the TPO failed to properly analyze the assessee's functions, risks, and operational profile, relying solely on the transfer pricing study without independent verification. The TPO erroneously compared the assessee, essentially a contract manufacturer without R&D activities, to large-scale enterprises with substantial independent research and higher turnovers. The matter was remanded to the TPO/AO for a fresh determination of arm's-length price, directing the assessee to submit comprehensive details on manufacturing processes, risks assumed, marketing, R&D activities, customer and supplier identification, and fresh comparability analysis reflecting the assessee's actual FAR profile. The TPO is to re-examine the issue and pass a reasoned order after affording the assessee a fair hearing. The appeal is allowed with these directions.
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TaxTMI 
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