https://www.taxtmi.com/caselaws?id=775169 Delhi HC set aside ITAT order in transfer pricing case involving comparable selection disputes. Assessee challenged inclusion of Comviva Technologies Ltd., arguing TPO and DRP conducted no analysis for its inclusion. ITAT rejected objection erroneously claiming entity was selected by both parties. Regarding Cybercom Datamatics Information Solutions Ltd., Assessee contended functional dissimilarity as it operates as consultant/advisor while Assessee is captive software developer. ITAT recorded submissions but provided no reasoning for accepting functional comparability or rejecting other entity objections. HC found ITAT failed to provide adequate reasons for conclusions and remanded matter for fresh consideration with reasoned order. en-us Wed, 09 Jul 2025 00:00:00 +0530 Mon, 21 Jul 2025 08:43:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775169 Delhi HC set aside ITAT order in transfer pricing case involving comparable selection disputes. Assessee challenged inclusion of Comviva Technologies Ltd., arguing TPO and DRP conducted no analysis for its inclusion. ITAT rejected objection erroneously claiming entity was selected by both parties. Regarding Cybercom Datamatics Information Solutions Ltd., Assessee contended functional dissimilarity as it operates as consultant/advisor while Assessee is captive software developer. ITAT recorded submissions but provided no reasoning for accepting functional comparability or rejecting other entity objections. HC found ITAT failed to provide adequate reasons for conclusions and remanded matter for fresh consideration with reasoned order. Case-Laws Income Tax Wed, 09 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775169