https://www.taxtmi.com/highlights?id=93285 ITAT allowed Ground No.2, holding that Company A is not a comparable for TP adjustment. The Tribunal accepted that Company A admitted to ROC it is exclusively a manufacturer, whereas the assessee conducts both manufacturing and trading; the TPO's 75% trading-turnover filter consequently excluded Company A. On this basis the AO/TPO is directed to delete Company A from the selected comparable set. The parties conceded that Company B's operating margin is 2.92%; accordingly the AO/TPO is directed to re-compute the comparable average and TP result incorporating Company B at a 2.92% margin. en-us Mon, 13 Oct 2025 08:54:01 +0530 Mon, 13 Oct 2025 08:54:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=93285 ITAT allowed Ground No.2, holding that Company A is not a comparable for TP adjustment. The Tribunal accepted that Company A admitted to ROC it is exclusively a manufacturer, whereas the assessee conducts both manufacturing and trading; the TPO's 75% trading-turnover filter consequently excluded Company A. On this basis the AO/TPO is directed to delete Company A from the selected comparable set. The parties conceded that Company B's operating margin is 2.92%; accordingly the AO/TPO is directed to re-compute the comparable average and TP result incorporating Company B at a 2.92% margin. Highlights Income Tax Mon, 13 Oct 2025 08:54:01 +0530 https://www.taxtmi.com/highlights?id=93285