TP adjustments without comparing them with similar transactions or comparables are uncalled for; cas

IT/ILT : Where in course of transfer pricing proceedings, TPO made adjustment in respect of excess price paid to AE located abroad for purchase of software, in view of fact that a comparison had to be done based on similar transactions entered either by assessee or by AE with third parties or other similarly placed entities for acquiring same items, impugned adjustment was to be set aside and, matter was to be remanded back for disposal afresh