https://www.taxtmi.com/caselaws?id=769555 The ITAT Mumbai held that the transfer pricing adjustment computation was incorrect, as the difference of INR 11,96,41,940/- between the arm's length price (INR 438,44,64,758/-) and actual sales (INR 426,48,22,811/-) should have been added as ALP adjustment rather than transfer pricing addition. The tribunal directed exclusion of MPS Limited from comparables due to functional dissimilarities and absence of segmental data, while ordering inclusion of R. Systems International Limited after examining functional comparability under TNMM method. Additionally, the AO was directed to grant DDT credit after verifying challans and re-compute consequential interest under Section 115P. en-us Mon, 07 Apr 2025 00:00:00 +0530 Mon, 28 Apr 2025 08:35:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769555 The ITAT Mumbai held that the transfer pricing adjustment computation was incorrect, as the difference of INR 11,96,41,940/- between the arm's length price (INR 438,44,64,758/-) and actual sales (INR 426,48,22,811/-) should have been added as ALP adjustment rather than transfer pricing addition. The tribunal directed exclusion of MPS Limited from comparables due to functional dissimilarities and absence of segmental data, while ordering inclusion of R. Systems International Limited after examining functional comparability under TNMM method. Additionally, the AO was directed to grant DDT credit after verifying challans and re-compute consequential interest under Section 115P. Case-Laws Income Tax Mon, 07 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769555