https://www.taxtmi.com/caselaws?id=763223 ITAT Visakhapatnam dismissed Revenue's appeal regarding transfer pricing adjustment. The case involved selection of tested party due to functional differences between associated enterprise and assessee regarding assets and risks. TPO rejected assessee's segmental results after choosing assessee as tested party. ITAT upheld CIT(A)'s decision, noting no additional segmental evidence was provided that wasn't already before AO. Tribunal agreed with exclusion of two export companies from arm's length range and confirmed that associated enterprise could only be compared with TPO-selected comparables due to functional similarity as tested party. en-us Mon, 15 Jul 2024 00:00:00 +0530 Sat, 14 Dec 2024 10:12:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763223 ITAT Visakhapatnam dismissed Revenue's appeal regarding transfer pricing adjustment. The case involved selection of tested party due to functional differences between associated enterprise and assessee regarding assets and risks. TPO rejected assessee's segmental results after choosing assessee as tested party. ITAT upheld CIT(A)'s decision, noting no additional segmental evidence was provided that wasn't already before AO. Tribunal agreed with exclusion of two export companies from arm's length range and confirmed that associated enterprise could only be compared with TPO-selected comparables due to functional similarity as tested party. Case-Laws Income Tax Mon, 15 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763223