https://www.taxtmi.com/caselaws?id=311893 The ITAT New Delhi held that certain comparables selected by the assessee were functionally dissimilar and therefore could not be considered valid for transfer pricing analysis; these included Killick Agencies Marketing Ltd., Febulka Advertising Pvt. Ltd., Info Edge India Ltd., and Interactive Manpower Solution. The AO was directed to exclude these from the comparable list. The AO was also instructed to re-examine and correctly compute margins for Sasken Network Engineering Ltd., Himachal Futuristic Communications Ltd., and Cameo Corporate Services Ltd. The issue of ALP adjustment for management service payments was restored to the TPO for fresh adjudication with detailed submissions. The disallowance of deduction under section 10AA was set aside and remanded to the AO for fresh verification of eligibility and completeness of information, as the DRP's reliance on prior decisions without fact verification was found improper. en-us Tue, 17 May 2022 00:00:00 +0530 Wed, 13 Aug 2025 12:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311893 The ITAT New Delhi held that certain comparables selected by the assessee were functionally dissimilar and therefore could not be considered valid for transfer pricing analysis; these included Killick Agencies Marketing Ltd., Febulka Advertising Pvt. Ltd., Info Edge India Ltd., and Interactive Manpower Solution. The AO was directed to exclude these from the comparable list. The AO was also instructed to re-examine and correctly compute margins for Sasken Network Engineering Ltd., Himachal Futuristic Communications Ltd., and Cameo Corporate Services Ltd. The issue of ALP adjustment for management service payments was restored to the TPO for fresh adjudication with detailed submissions. The disallowance of deduction under section 10AA was set aside and remanded to the AO for fresh verification of eligibility and completeness of information, as the DRP's reliance on prior decisions without fact verification was found improper. Case-Laws Income Tax Tue, 17 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311893