https://www.taxtmi.com/caselaws?id=459397 The court upheld the ITAT's decision, affirming the CIT(A)'s order that set aside the TPO's determination. The appeal was dismissed as the court found no substantial question of law. The court emphasized the necessity of compelling reasons for the Revenue to deviate from settled positions and highlighted the inconsistency in the TPO's acceptance of comparables. The CIT(A)'s allowance of working capital adjustments was validated, as the Revenue failed to present distinguishing features to contest it. The judgment reinforced the requirement for adherence to established tax rules and the proper consideration of comparables in transfer pricing analysis. en-us Wed, 07 Aug 2024 00:00:00 +0530 Wed, 11 Dec 2024 18:57:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459397 The court upheld the ITAT's decision, affirming the CIT(A)'s order that set aside the TPO's determination. The appeal was dismissed as the court found no substantial question of law. The court emphasized the necessity of compelling reasons for the Revenue to deviate from settled positions and highlighted the inconsistency in the TPO's acceptance of comparables. The CIT(A)'s allowance of working capital adjustments was validated, as the Revenue failed to present distinguishing features to contest it. The judgment reinforced the requirement for adherence to established tax rules and the proper consideration of comparables in transfer pricing analysis. Case-Laws Income Tax Wed, 07 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459397