https://www.taxtmi.com/caselaws?id=122985 The Tribunal's judgment involved a detailed analysis of the selection of comparables, adjustments for risk profiles, and the treatment of unrealized foreign exchange gains. The issues were largely restored to the AO for fresh consideration in light of previous decisions and specific case facts, emphasizing the need for functional similarity in transfer pricing analysis. The Tribunal upheld the inclusion of M/s Ujjwal Limited as a comparable case but set aside the CIT(A)'s order on the inclusion of Vimta Labs Ltd., directing the AO to reconsider based on submissions and relevant case law. The Tribunal also supported the deletion of addition in respect of unrealized foreign exchange gain. en-us Fri, 28 Jan 2011 00:00:00 +0530 Mon, 21 Aug 2023 17:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=122985 The Tribunal's judgment involved a detailed analysis of the selection of comparables, adjustments for risk profiles, and the treatment of unrealized foreign exchange gains. The issues were largely restored to the AO for fresh consideration in light of previous decisions and specific case facts, emphasizing the need for functional similarity in transfer pricing analysis. The Tribunal upheld the inclusion of M/s Ujjwal Limited as a comparable case but set aside the CIT(A)'s order on the inclusion of Vimta Labs Ltd., directing the AO to reconsider based on submissions and relevant case law. The Tribunal also supported the deletion of addition in respect of unrealized foreign exchange gain. Case-Laws Income Tax Fri, 28 Jan 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122985