https://www.taxtmi.com/caselaws?id=258076 ITAT Mumbai upheld exclusion of certain comparables (DIKL, SCL, MIL, PIL) from the transfer pricing analysis due to lack of functional comparability or exceptional circumstances, directing ALP determination based on Atul Ltd. and IG Petrochemicals Ltd. only. The scope of adjustment was confined to international transactions between AEs. On management service charges paid to AEs, the matter was remanded for fresh adjudication after granting the assessee a reasonable opportunity to prove services availed and ALP compliance. Regarding section 145A adjustments for closing stock valuation, the ITAT set aside the impugned order, directing the AO to apply the inclusive valuation method consistent with statutory mandate and judicial precedents, ruling in favor of the assessee for statistical purposes. en-us Fri, 18 Jan 2013 00:00:00 +0530 Sat, 04 Jul 2026 13:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=258076 ITAT Mumbai upheld exclusion of certain comparables (DIKL, SCL, MIL, PIL) from the transfer pricing analysis due to lack of functional comparability or exceptional circumstances, directing ALP determination based on Atul Ltd. and IG Petrochemicals Ltd. only. The scope of adjustment was confined to international transactions between AEs. On management service charges paid to AEs, the matter was remanded for fresh adjudication after granting the assessee a reasonable opportunity to prove services availed and ALP compliance. Regarding section 145A adjustments for closing stock valuation, the ITAT set aside the impugned order, directing the AO to apply the inclusive valuation method consistent with statutory mandate and judicial precedents, ruling in favor of the assessee for statistical purposes. Case-Laws Income Tax Fri, 18 Jan 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=258076