Transfer Pricing Dispute Resolved: Comprehensive Reassessment Ordered with Full Restoration of Disputed Issues to Tax Authorities

ITAT adjudicated transfer pricing dispute involving manufacturing and service segments. Tribunal found substantial merit in assessee's contentions regarding arm's length pricing methodology. Key objections included improper comparability analysis, incorrect application of transfer pricing principles, and disregard of multiple year data. The Tribunal comprehensively restored all disputed issues to TPO/AO for fresh determination, directing a de novo examination of transfer pricing adjustments. The appellate order allows the assessee to submit additional evidence and mandates the lower authorities to pass a reasoned order consistent with legal principles. Appeal allowed for statistical purposes with directions for comprehensive re-examination of transfer pricing computations. .....

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