Transfer Pricing Dispute Resolved: ITAT Mandates ALP Recalculation and Comparables Adjustment Under Precise Procedural Guidelines

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....ITAT adjudicated transfer pricing dispute, directing significant procedural adjustments. The tribunal found computational discrepancies in Arm's Length Price (ALP), mandating TPO to recalculate transfer pricing adjustment of INR 11,96,41,940. Specifically, ITAT instructed exclusion of MPS Limited from comparables list due to functional dissimilarities and directed inclusion of R. Systems International Limited after functional comparability assessment. Additionally, the tribunal mandated AO to grant full credit for Dividend Distribution Tax (DDT) upon verification of submitted challans and recompute potential interest under Section 115P, effectively resolving multiple taxation-related contentions through precise administrative directions.....