https://www.taxtmi.com/caselaws?id=245702 ITAT MUMBAI held in favour of the assessee, directing that the A.O./TPO reassess the transfer pricing adjustment. The tribunal found the assessee to be a job worker/contract manufacturer entitled to cost-plus charges, and that the comparables selected by TPO (full-scale independent manufacturers) were prima facie inappropriate. ITAT ordered that direct methods (CUP, RPM, CPM) be considered first and TNMM used only if those are inapplicable, remanding the matter to the AO/TPO for fresh adjudication. en-us Wed, 23 Oct 2013 00:00:00 +0530 Mon, 01 Sep 2025 10:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=245702 ITAT MUMBAI held in favour of the assessee, directing that the A.O./TPO reassess the transfer pricing adjustment. The tribunal found the assessee to be a job worker/contract manufacturer entitled to cost-plus charges, and that the comparables selected by TPO (full-scale independent manufacturers) were prima facie inappropriate. ITAT ordered that direct methods (CUP, RPM, CPM) be considered first and TNMM used only if those are inapplicable, remanding the matter to the AO/TPO for fresh adjudication. Case-Laws Income Tax Wed, 23 Oct 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=245702