https://www.taxtmi.com/caselaws?id=781592 Transfer pricing disputes concerning the ITES and manufacturing segments were remitted for fresh FAR-based examination, with the Tribunal holding that the MAP-determined margin could be applied to non-UK transactions only after verifying whether the price-influencing factors were materially similar. The ITES adjustment was therefore set aside for reconsideration by the TPO/AO. The management charges issue did not survive independently because it was covered by the MAP settlement and was treated as withdrawn. The manufacturing segment adjustment was also set aside, as the comparables, functional similarity, product profile, and filter application required fresh benchmarking. en-us Thu, 30 Oct 2025 00:00:00 +0530 Fri, 14 Nov 2025 17:45:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781592 Transfer pricing disputes concerning the ITES and manufacturing segments were remitted for fresh FAR-based examination, with the Tribunal holding that the MAP-determined margin could be applied to non-UK transactions only after verifying whether the price-influencing factors were materially similar. The ITES adjustment was therefore set aside for reconsideration by the TPO/AO. The management charges issue did not survive independently because it was covered by the MAP settlement and was treated as withdrawn. The manufacturing segment adjustment was also set aside, as the comparables, functional similarity, product profile, and filter application required fresh benchmarking. Case-Laws Income Tax Thu, 30 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781592