https://www.taxtmi.com/highlights?id=88581 ITAT allowed taxpayer's appeal, rejecting transfer pricing adjustment of INR 30,264,835. The tribunal found merit in the argument that internal comparables should not be dismissed solely based on transaction volume. Referencing a prior Delhi HC decision, the tribunal held that comparable entities cannot be automatically rejected due to size disparity. The lower authorities erred in disqualifying the assessee's internal non-arm's length transaction profitability comparison. Consequently, the arm's length price (ALP) adjustment was deleted, affirming the taxpayer's transfer pricing methodology as justified. en-us Wed, 21 May 2025 08:29:07 +0530 Wed, 21 May 2025 08:29:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=88581 ITAT allowed taxpayer's appeal, rejecting transfer pricing adjustment of INR 30,264,835. The tribunal found merit in the argument that internal comparables should not be dismissed solely based on transaction volume. Referencing a prior Delhi HC decision, the tribunal held that comparable entities cannot be automatically rejected due to size disparity. The lower authorities erred in disqualifying the assessee's internal non-arm's length transaction profitability comparison. Consequently, the arm's length price (ALP) adjustment was deleted, affirming the taxpayer's transfer pricing methodology as justified. Highlights Income Tax Wed, 21 May 2025 08:29:07 +0530 https://www.taxtmi.com/highlights?id=88581