Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
The ITAT held that the comparable company selected by the TPO for transfer pricing adjustment did not match the functional profile of the assessee and thus must be excluded from the comparable set. Regarding other comparables, the tribunal directed the AO/TPO to reconsider their inclusion afresh, applying appropriate filters and providing the assessee a reasonable opportunity to be heard and submit supporting documents. The appeal was partly allowed for statistical purposes, remanding the matter for further examination consistent with the directions.
The ITAT held that the comparable company selected by the TPO for transfer pricing adjustment did not match the functional profile of the assessee and thus must be excluded from the comparable set. Regarding other comparables, the tribunal directed the AO/TPO to reconsider their inclusion afresh, applying appropriate filters and providing the assessee a reasonable opportunity to be heard and submit supporting documents. The appeal was partly allowed for statistical purposes, remanding the matter for further examination consistent with the directions.
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