ITAT Directs Fresh TP Analysis as TPO Mechanically Rejected Segmental Results

Curia India Private Limited Vs DCIT (ITAT Hyderabad) The appeal before the ITAT Hyderabad arose from the assessment order passed under Section 143(3) read with Section 144C(13) of the Income-tax Act for Assessment Year 2018-19. The assessee, a wholly owned subsidiary of the Curia Group engaged in providing contract research and development (R&D) services and contract manufacturing services to its associated enterprises (AEs), challenged multiple transfer pricing (TP) adjustments made by the Transfer Pricing Officer (TPO) and upheld substantially by the Dispute Resolution Panel (DRP). The a...