https://www.taxtmi.com/caselaws?id=774586 ITAT Delhi ruled on transfer pricing adjustment concerning comparable selection for computing arm's length price. The assessee challenged TPO's selection of comparables in TP study. ITAT excluded certain comparables including Sagarsoft India Limited as not functionally similar to assessee, following coordinate bench precedent. However, ITAT included other comparables deemed functionally similar, previously approved in assessee's own case. Matter remanded to TPO for fresh ALP computation with revised comparable list. TPO directed to exclude/include specified comparables and recompute ALP, with no adjustment required if within +1% tolerance range. en-us Fri, 09 May 2025 00:00:00 +0530 Fri, 11 Jul 2025 08:39:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774586 ITAT Delhi ruled on transfer pricing adjustment concerning comparable selection for computing arm's length price. The assessee challenged TPO's selection of comparables in TP study. ITAT excluded certain comparables including Sagarsoft India Limited as not functionally similar to assessee, following coordinate bench precedent. However, ITAT included other comparables deemed functionally similar, previously approved in assessee's own case. Matter remanded to TPO for fresh ALP computation with revised comparable list. TPO directed to exclude/include specified comparables and recompute ALP, with no adjustment required if within +1% tolerance range. Case-Laws Income Tax Fri, 09 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774586