https://www.taxtmi.com/caselaws?id=446722 The ITAT Delhi allowed the assessee's application for admission of additional evidence regarding transfer pricing comparables. The assessee had erroneously selected companies engaged in financial and leasing services instead of business support services to benchmark international transactions. The Tribunal found both the assessee and TPO were mistaken about the functional profile, leading to incorrect comparable selection. Despite Rule 29 generally barring additional evidence, the Tribunal exercised discretion given the substantial cause and contemporaneous nature of the evidence. The assessment order was set aside, directing the TPO to accept fresh evidence and pass a new order after providing hearing opportunity. The appeal was allowed for statistical purposes. en-us Thu, 30 Nov 2023 00:00:00 +0530 Mon, 10 Jun 2024 17:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446722 The ITAT Delhi allowed the assessee's application for admission of additional evidence regarding transfer pricing comparables. The assessee had erroneously selected companies engaged in financial and leasing services instead of business support services to benchmark international transactions. The Tribunal found both the assessee and TPO were mistaken about the functional profile, leading to incorrect comparable selection. Despite Rule 29 generally barring additional evidence, the Tribunal exercised discretion given the substantial cause and contemporaneous nature of the evidence. The assessment order was set aside, directing the TPO to accept fresh evidence and pass a new order after providing hearing opportunity. The appeal was allowed for statistical purposes. Case-Laws Income Tax Thu, 30 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446722