Delhi HC Sets Aside ITAT Order For Lack Of Reasoned Findings On Functional Comparability

The Delhi High Court set aside an ITAT order in a transfer pricing dispute for lack of reasoned findings. The Court emphasized that the Tribunal must analyze functions, assets, and risks to determine comparability between companies. The judgment reinforces that judicial and quasi-judicial bodies must deliver speaking orders with proper reasoning. This decision underscores the need for transparency and fairness in transfer pricing adjudication, ensuring consistency in international taxation matters.