https://www.taxtmi.com/caselaws?id=776407 ITAT Bangalore held that the TPO failed to properly analyze the assessee's functions, risks, and activities, relying solely on the transfer pricing report without verification. The assessee was found to be primarily an assembler or contract manufacturer without significant R&D, unlike the large comparables used by the TPO. The matter was remanded to the TPO/AO for a fresh comparability analysis considering the assessee's actual functions, risks, marketing, and R&D activities. The assessee was directed to submit detailed information and a revised comparability study. The TPO was instructed to re-examine the arm's-length price after providing the assessee an opportunity of hearing. The ground was allowed with these directions. en-us Fri, 18 Jul 2025 00:00:00 +0530 Sat, 09 Aug 2025 09:32:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776407 ITAT Bangalore held that the TPO failed to properly analyze the assessee's functions, risks, and activities, relying solely on the transfer pricing report without verification. The assessee was found to be primarily an assembler or contract manufacturer without significant R&D, unlike the large comparables used by the TPO. The matter was remanded to the TPO/AO for a fresh comparability analysis considering the assessee's actual functions, risks, marketing, and R&D activities. The assessee was directed to submit detailed information and a revised comparability study. The TPO was instructed to re-examine the arm's-length price after providing the assessee an opportunity of hearing. The ground was allowed with these directions. Case-Laws Income Tax Fri, 18 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776407