https://www.taxtmi.com/caselaws?id=391395 ITAT set aside transfer-pricing margin determination to the TPO for fresh fact-finding and held the consolidated financials of a group company are not comparable with the assessee, directing that that group entity be excluded as a comparable. Inclusion of another potential comparable was not decided. The Tribunal deleted an ad hoc disallowance of management-fee reimbursements, limited any TP adjustments to the amount of international transactions, directed application of a +5% adjustment benefit, allowed specified tax-incentive deduction, and left the low-value asset deduction issue for verification as directed by the DRP. en-us Wed, 22 Jan 2020 00:00:00 +0530 Fri, 22 Aug 2025 22:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=391395 ITAT set aside transfer-pricing margin determination to the TPO for fresh fact-finding and held the consolidated financials of a group company are not comparable with the assessee, directing that that group entity be excluded as a comparable. Inclusion of another potential comparable was not decided. The Tribunal deleted an ad hoc disallowance of management-fee reimbursements, limited any TP adjustments to the amount of international transactions, directed application of a +5% adjustment benefit, allowed specified tax-incentive deduction, and left the low-value asset deduction issue for verification as directed by the DRP. Case-Laws Income Tax Wed, 22 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=391395