Manufacturing Comparable Fails 75% Trading Turnover Test, Excluded from TP Analysis

B & R Industrial Automation Pvt. Ltd Vs Additional / Joint/ Deputy / ACIT /ITO (ITAT Pune) The appeal before the Income Tax Appellate Tribunal, Pune, arose from a final assessment order dated 26 September 2024 passed under sections 143(3) read with 144C(13) and 144B of the Income-tax Act, 1961, pursuant to directions of the Dispute Resolution Panel (DRP). The assessee, engaged in the business of trading programmable logic controllers and importing its trading goods from its holding company, reported a total income of ₹98.70 crore. The Assessing Officer, following transfer pricing adjustm...