Transfer Pricing Dispute Resolved: Tribunal Directs Rectification, Validates Comparable Company Analysis and Expense Reporting

ITAT adjudicated a transfer pricing dispute involving TP adjustments and comparable company analysis. The tribunal found merit in the assessee's contention regarding rectification order and directed the Assessing Officer to implement the TPO's revised order dated 24th February, 2023. Comparable companies were deselected based on functional dissimilarity. Regarding PF/LWF contribution delays, the tribunal allowed the assessee's grounds subject to verification of suo motto disallowance, noting prior period expense reporting and a pending rectification application for assessment years 2015-16 and 2016-17. .....

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