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The ITAT affirmed that the TPO lawfully included Comparable Company A in the comparable set for transfer pricing purposes, finding functional comparability with the assessee's provision of IT-enabled services notwithstanding lower turnover, and held that the CIT(A)'s exclusion was unsustainable. The ITAT also addressed the CIT(A)'s direction regarding Comparable Companies B and C and the working-capital adjustment, noting the assessee's appeal-effect submission to the AO; the impugned orders were set aside and the matter remanded to the AO for fresh adjudication on those issues. The appeal is allowed in part for statistical purposes, with directions for reconsideration consistent with the Tribunal's findings.
The ITAT affirmed that the TPO lawfully included Comparable Company A in the comparable set for transfer pricing purposes, finding functional comparability with the assessee's provision of IT-enabled services notwithstanding lower turnover, and held that the CIT(A)'s exclusion was unsustainable. The ITAT also addressed the CIT(A)'s direction regarding Comparable Companies B and C and the working-capital adjustment, noting the assessee's appeal-effect submission to the AO; the impugned orders were set aside and the matter remanded to the AO for fresh adjudication on those issues. The appeal is allowed in part for statistical purposes, with directions for reconsideration consistent with the Tribunal's findings.
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