https://www.taxtmi.com/caselaws?id=462948 ITAT DELHI held that the distinction between core and non-core auto components is essential for transfer pricing comparability. The Tribunal rejected the CIT(A)'s exclusion of comparables without proper FAR analysis and found that companies manufacturing core components cannot be compared with those producing non-core components like the taxpayer. Comparables suggested by the taxpayer were also found unsuitable based on product comparability. The Tribunal declined conditional remand due to inadequate TP analysis by the TPO and CIT(A), directing a fresh open-ended TP study considering product comparability and core/non-core distinction. The issue of applying the arm's length range benefit under section 92C(2) was remitted to the TPO for fresh adjudication. The Revenue's appeal was allowed for statistical purposes. en-us Tue, 31 Dec 2019 00:00:00 +0530 Wed, 23 Jul 2025 17:07:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462948 ITAT DELHI held that the distinction between core and non-core auto components is essential for transfer pricing comparability. The Tribunal rejected the CIT(A)'s exclusion of comparables without proper FAR analysis and found that companies manufacturing core components cannot be compared with those producing non-core components like the taxpayer. Comparables suggested by the taxpayer were also found unsuitable based on product comparability. The Tribunal declined conditional remand due to inadequate TP analysis by the TPO and CIT(A), directing a fresh open-ended TP study considering product comparability and core/non-core distinction. The issue of applying the arm's length range benefit under section 92C(2) was remitted to the TPO for fresh adjudication. The Revenue's appeal was allowed for statistical purposes. Case-Laws Income Tax Tue, 31 Dec 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462948