Order not providing reasons on functionality of comparable for transfer pricing adjustment cannot sustain

TPG Software Pvt Ltd Vs DCIT (Delhi High Court) Delhi High Court held that order is liable to be set aside and matter remanded to ITAT since ITAT failed to provide appropriate reasoning with regard to functionality of comparable while undertaking transfer pricing adjustment. Facts- During scrutiny assessment, TPO passed an order u/s. 92CA(3) of the Act proposing a transfer pricing adjustment of ₹6,84,70,678/- in respect of international transactions, which related to provision of software development services provided by the Assessee to its overseas associated enterprises as well as interes...