https://www.taxtmi.com/caselaws?id=767883 ITAT Delhi remitted TP adjustment issue back to AO/TPO after finding TPO misunderstood assessee's business model and wrongly rejected RPM method despite Revenue's acceptance in earlier years for trading segment. TPO failed to properly analyze assessee's dual manufacturing and trading activities. Court also remitted expenditure disallowance matter for verification of additional evidence after assessee couldn't establish genuineness of expenses. Addition under section 69C based solely on CBEC import data was remitted back as AO lacked customs duty payment details and proper reconciliation of imports. en-us Fri, 21 Mar 2025 00:00:00 +0530 Thu, 27 Mar 2025 08:36:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767883 ITAT Delhi remitted TP adjustment issue back to AO/TPO after finding TPO misunderstood assessee's business model and wrongly rejected RPM method despite Revenue's acceptance in earlier years for trading segment. TPO failed to properly analyze assessee's dual manufacturing and trading activities. Court also remitted expenditure disallowance matter for verification of additional evidence after assessee couldn't establish genuineness of expenses. Addition under section 69C based solely on CBEC import data was remitted back as AO lacked customs duty payment details and proper reconciliation of imports. Case-Laws Income Tax Fri, 21 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767883