https://www.taxtmi.com/highlights?id=94267 The ITAT set aside the impugned transfer-pricing adjustments and remitted issues to the AO/TPO for fresh determination. With respect to the ITES segment, the Tribunal directed a detailed FAR analysis of transactions with non-UK AEs to assess comparability with UK transactions resolved under the MAP; if comparable, the 18% operating-cost margin agreed by the Competent Authorities shall be applied. The manufacturing-segment comparables were also remitted for a fresh FAR and comparability analysis, with specific instruction to apply related-party, import/export and turnover filters under Rules 10B(2)-10B(3). The addition relating to management charges was dismissed as withdrawn. The assessee to be afforded opportunity of hearing and to furnish documentation. en-us Tue, 18 Nov 2025 08:42:58 +0530 Tue, 18 Nov 2025 08:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=94267 The ITAT set aside the impugned transfer-pricing adjustments and remitted issues to the AO/TPO for fresh determination. With respect to the ITES segment, the Tribunal directed a detailed FAR analysis of transactions with non-UK AEs to assess comparability with UK transactions resolved under the MAP; if comparable, the 18% operating-cost margin agreed by the Competent Authorities shall be applied. The manufacturing-segment comparables were also remitted for a fresh FAR and comparability analysis, with specific instruction to apply related-party, import/export and turnover filters under Rules 10B(2)-10B(3). The addition relating to management charges was dismissed as withdrawn. The assessee to be afforded opportunity of hearing and to furnish documentation. Highlights Income Tax Tue, 18 Nov 2025 08:42:58 +0530 https://www.taxtmi.com/highlights?id=94267