Taxpayer wins partial transfer pricing relief under s.92C after two group entities excluded as non-comparables

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....ITAT allowed the taxpayer's challenge to part of the transfer pricing adjustment under s.92C, directing the TPO to exclude two large group entities from the comparable set as non-comparable due to disproportionate turnover and distinctive brand-derived market advantages, and to recompute the ALP shortfall accordingly. The Tribunal affirmed the DRP's exclusion of several comparables that never featured in the TPO's search/accept-reject matrix, finding such inclusion would amount to impermissible cherry-picking. The Tribunal upheld the TPO's retention of another comparable on margin grounds and rejected the assessee's merger-impact contention. The AO was directed to verify and apply statutory set-off of current year losses when computing taxable income.....