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The ITAT held that the TPO's benchmarking exercise was procedurally flawed because, having applied a lower turnover threshold of Rs. 1.00 crore in comparable selection, the TPO ought also to have applied an appropriate upper turnover limit; consequently the Tribunal remanded the matter to the AO/TPO for a fresh transfer-pricing comparability analysis incorporating an upper turnover filter. All other substantive and procedural contentions raised by the appellant are left open for reconsideration by the AO/TPO. The appeal by the appellant is accordingly partly allowed for statistical purposes and the final transfer-pricing determination is to be reworked consistent with this direction.
The ITAT held that the TPO's benchmarking exercise was procedurally flawed because, having applied a lower turnover threshold of Rs. 1.00 crore in comparable selection, the TPO ought also to have applied an appropriate upper turnover limit; consequently the Tribunal remanded the matter to the AO/TPO for a fresh transfer-pricing comparability analysis incorporating an upper turnover filter. All other substantive and procedural contentions raised by the appellant are left open for reconsideration by the AO/TPO. The appeal by the appellant is accordingly partly allowed for statistical purposes and the final transfer-pricing determination is to be reworked consistent with this direction.
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