https://www.taxtmi.com/caselaws?id=463418 ITAT (Bangalore) partly allowed the appeal, directing the TPO to exclude from the comparable set companies with turnover exceeding Rs. 200 crores and to recompute the ALP under TNMM accordingly. The Tribunal applied a symmetric upper-turnover filter, finding size materially affects comparability and followed coordinate-bench precedent favouring the Rs. 200 crore cut-off. All other grounds in the appeal were not adjudicated because the appellant withdrew or did not press them at hearing; the Tribunal confined its decision to the pressed turnover issue, leaving unpressed issues open for future contest. en-us Wed, 04 Sep 2024 00:00:00 +0530 Mon, 01 Sep 2025 19:17:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463418 ITAT (Bangalore) partly allowed the appeal, directing the TPO to exclude from the comparable set companies with turnover exceeding Rs. 200 crores and to recompute the ALP under TNMM accordingly. The Tribunal applied a symmetric upper-turnover filter, finding size materially affects comparability and followed coordinate-bench precedent favouring the Rs. 200 crore cut-off. All other grounds in the appeal were not adjudicated because the appellant withdrew or did not press them at hearing; the Tribunal confined its decision to the pressed turnover issue, leaving unpressed issues open for future contest. Case-Laws Income Tax Wed, 04 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463418