https://www.taxtmi.com/caselaws?id=72043 The Tribunal allowed the appeal, declaring the TPO's order legally and factually flawed. It affirmed that the assessee's international transactions were at arm's length. The Tribunal underscored necessary adjustments for risk profiles, working capital, and accounting policies, and mandated the application of the +/(-) 5% variance under proviso to s. 92C(2). It also emphasized the principle of res judicata and criticized the AO for not independently verifying facts before computing total income based on the TPO's order. en-us Fri, 26 Sep 2008 00:00:00 +0530 Wed, 05 Jun 2024 17:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=72043 The Tribunal allowed the appeal, declaring the TPO's order legally and factually flawed. It affirmed that the assessee's international transactions were at arm's length. The Tribunal underscored necessary adjustments for risk profiles, working capital, and accounting policies, and mandated the application of the +/(-) 5% variance under proviso to s. 92C(2). It also emphasized the principle of res judicata and criticized the AO for not independently verifying facts before computing total income based on the TPO's order. Case-Laws Income Tax Fri, 26 Sep 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=72043