https://www.taxtmi.com/caselaws?id=768881 The ITAT Delhi remanded the transfer pricing case back to the TPO/AO for fresh determination. The assessee challenged TP adjustments in manufacturing segment, arguing TPO failed to apply transaction-by-transaction approach despite additional evidence and previous tribunal directions. Key objections included improper ALP application, disregard of comparable company selection criteria, exclusion of working capital adjustments, and failure to consider R&D and business support service segments. The tribunal found merit in assessee's contentions regarding errors by lower authorities and directed fresh examination of all issues with speaking orders in accordance with law. en-us Wed, 09 Apr 2025 00:00:00 +0530 Tue, 15 Apr 2025 08:35:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768881 The ITAT Delhi remanded the transfer pricing case back to the TPO/AO for fresh determination. The assessee challenged TP adjustments in manufacturing segment, arguing TPO failed to apply transaction-by-transaction approach despite additional evidence and previous tribunal directions. Key objections included improper ALP application, disregard of comparable company selection criteria, exclusion of working capital adjustments, and failure to consider R&D and business support service segments. The tribunal found merit in assessee's contentions regarding errors by lower authorities and directed fresh examination of all issues with speaking orders in accordance with law. Case-Laws Income Tax Wed, 09 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768881