https://www.taxtmi.com/caselaws?id=463413 ITAT DELHI remanded the transfer-pricing issue to the TPO for fresh determination, finding that the comparables used by both sides were inappropriate. The tribunal noted failure to account for foreign-exchange fluctuations and possible under-utilisation of capacity, and held that only entities primarily engaged in job work/contract manufacturing should be used as comparables. The TPO was directed to identify suitable job-worker comparables, obtain relevant benchmarking data, re-decide the matter and afford the assessee a reasonable opportunity of hearing. en-us Thu, 13 Nov 2014 00:00:00 +0530 Mon, 01 Sep 2025 19:17:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463413 ITAT DELHI remanded the transfer-pricing issue to the TPO for fresh determination, finding that the comparables used by both sides were inappropriate. The tribunal noted failure to account for foreign-exchange fluctuations and possible under-utilisation of capacity, and held that only entities primarily engaged in job work/contract manufacturing should be used as comparables. The TPO was directed to identify suitable job-worker comparables, obtain relevant benchmarking data, re-decide the matter and afford the assessee a reasonable opportunity of hearing. Case-Laws Income Tax Thu, 13 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463413