Transfer Pricing Addition Sent Back as DRP Failed to Properly Examine Functional Comparability

TGS Minmet Private Limited Vs DCIT (ITAT Visakhapatnam) ITAT Remands ₹5.51 Crore TP Adjustment Due to Doubt Over Trading and Manufacturing Comparables;  ITAT Grants Fresh Opportunity in TP Case Involving COVID-19 Transportation Costs and Comparables;  Manufacturing Companies Cannot Be Compared With Pure Traders Without Proper Analysis; ₹5.51 Crore ALP Adjustment Reconsideration Ordered Due to Inadequate DRP Findings. The Income Tax Appellate Tribunal (ITAT), Visakhapatnam Bench, considered an appeal filed against the assessment order passed under Sections 143(3), 144C(13), and 144B of th...