https://www.taxtmi.com/caselaws?id=310604 The ITAT Bangalore remanded transfer pricing issues back to the DRP for fresh examination after finding the original DRP order cryptic regarding comparable selection, particularly the exclusion of Persistent Systems Solutions Ltd without detailed findings. The tribunal followed its earlier decision in the assessee's appeal and allowed Revenue's grounds. Issues concerning foreign exchange loss, risk adjustment, and comparable company inclusion/exclusion were also remanded to the DRP for denovo examination with proper opportunity of hearing. The tribunal emphasized that only forex gains/losses with nexus to the year's transactions should be considered, following the Mercedes Benz precedent. en-us Fri, 05 Apr 2019 00:00:00 +0530 Thu, 02 Nov 2023 19:16:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310604 The ITAT Bangalore remanded transfer pricing issues back to the DRP for fresh examination after finding the original DRP order cryptic regarding comparable selection, particularly the exclusion of Persistent Systems Solutions Ltd without detailed findings. The tribunal followed its earlier decision in the assessee's appeal and allowed Revenue's grounds. Issues concerning foreign exchange loss, risk adjustment, and comparable company inclusion/exclusion were also remanded to the DRP for denovo examination with proper opportunity of hearing. The tribunal emphasized that only forex gains/losses with nexus to the year's transactions should be considered, following the Mercedes Benz precedent. Case-Laws Income Tax Fri, 05 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310604