https://www.taxtmi.com/caselaws?id=463778 ITAT Delhi upheld the AO's reference to the TPO as valid. RPM was rejected and TNMM affirmed as the most appropriate method. Use of contemporaneous/current-year comparables was sustained; the TPO/DRP's comparable selection and search methodology were upheld except that the Tribunal remanded the turnover-filter issue to the DRP/AO for fresh consideration with opportunity to be heard. The amended proviso to s.92C(2) (+/-5%) was held applicable but did not yield relief here. Initiation of penalty proceedings was dismissed as non-appealable; interest under ss.234B/234D was sustained. Appeal otherwise dismissed/partly allowed for remand. en-us Fri, 31 Aug 2012 00:00:00 +0530 Tue, 16 Sep 2025 12:38:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463778 ITAT Delhi upheld the AO's reference to the TPO as valid. RPM was rejected and TNMM affirmed as the most appropriate method. Use of contemporaneous/current-year comparables was sustained; the TPO/DRP's comparable selection and search methodology were upheld except that the Tribunal remanded the turnover-filter issue to the DRP/AO for fresh consideration with opportunity to be heard. The amended proviso to s.92C(2) (+/-5%) was held applicable but did not yield relief here. Initiation of penalty proceedings was dismissed as non-appealable; interest under ss.234B/234D was sustained. Appeal otherwise dismissed/partly allowed for remand. Case-Laws Income Tax Fri, 31 Aug 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463778