https://www.taxtmi.com/highlights?id=93027 The ITAT held that the TPO's benchmarking exercise was procedurally flawed because, having applied a lower turnover threshold of Rs. 1.00 crore in comparable selection, the TPO ought also to have applied an appropriate upper turnover limit; consequently the Tribunal remanded the matter to the AO/TPO for a fresh transfer-pricing comparability analysis incorporating an upper turnover filter. All other substantive and procedural contentions raised by the appellant are left open for reconsideration by the AO/TPO. The appeal by the appellant is accordingly partly allowed for statistical purposes and the final transfer-pricing determination is to be reworked consistent with this direction. en-us Fri, 03 Oct 2025 08:30:38 +0530 Fri, 03 Oct 2025 08:30:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=93027 The ITAT held that the TPO's benchmarking exercise was procedurally flawed because, having applied a lower turnover threshold of Rs. 1.00 crore in comparable selection, the TPO ought also to have applied an appropriate upper turnover limit; consequently the Tribunal remanded the matter to the AO/TPO for a fresh transfer-pricing comparability analysis incorporating an upper turnover filter. All other substantive and procedural contentions raised by the appellant are left open for reconsideration by the AO/TPO. The appeal by the appellant is accordingly partly allowed for statistical purposes and the final transfer-pricing determination is to be reworked consistent with this direction. Highlights Income Tax Fri, 03 Oct 2025 08:30:38 +0530 https://www.taxtmi.com/highlights?id=93027