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2019 (1) TMI 884 - AT - Income TaxTPA - Comparable selection - assessee is involved in two different activities of manufacture and sale - Held that:- Assessee is into manufacture of compressors and also sale of compressors and both the activities are different and therefore, they require different set of comparables. Therefore, we deem it fit and proper to remit the issue to the file of AO/TPO for fresh analysis and fresh determination of ALP in accordance with law. Assessee shall be allowed to raise any contentions on account of comparables and also the method to be adopted for determination of the ALP. Grounds are thus considered as allowed for statistical purposes.
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