https://www.taxtmi.com/caselaws?id=265121 ITAT Delhi set aside the order of CIT(A)/DRP in a transfer pricing dispute involving characterization of the assessee's business model and selection of comparables. The Tribunal held that the assessee's contention regarding differing intensity of functions in AE and non-AE transactions, crucial for proper functional characterization, had not been examined either by the TPO or DRP. As this omission undermined the entire basis for the TP adjustment and for exclusion/retention of comparables, the impugned order was vacated. All issues raised in both assessee's and Revenue's appeals were remanded to AO/TPO for de novo adjudication with a speaking order after affording adequate opportunity of hearing. en-us Fri, 04 Sep 2015 00:00:00 +0530 Mon, 15 Dec 2025 17:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=265121 ITAT Delhi set aside the order of CIT(A)/DRP in a transfer pricing dispute involving characterization of the assessee's business model and selection of comparables. The Tribunal held that the assessee's contention regarding differing intensity of functions in AE and non-AE transactions, crucial for proper functional characterization, had not been examined either by the TPO or DRP. As this omission undermined the entire basis for the TP adjustment and for exclusion/retention of comparables, the impugned order was vacated. All issues raised in both assessee's and Revenue's appeals were remanded to AO/TPO for de novo adjudication with a speaking order after affording adequate opportunity of hearing. Case-Laws Income Tax Fri, 04 Sep 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=265121