https://www.taxtmi.com/caselaws?id=219910 The Tribunal upheld the CIT(A)'s decision to delete the addition made by the AO for the difference in arm's length price, citing the application of Section 92(3) and lack of adjustment necessity. The excess receipt from sales to the AE was classified as business income, not income from other sources. The Tribunal emphasized the requirement for detailed justification for adjustments under Section 80-IA(10), referencing the Tweezerman (India) case. Consequently, both the Revenue's appeal and the assessee's cross-objection were dismissed. en-us Tue, 18 Sep 2012 00:00:00 +0530 Thu, 27 Dec 2012 11:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=219910 The Tribunal upheld the CIT(A)'s decision to delete the addition made by the AO for the difference in arm's length price, citing the application of Section 92(3) and lack of adjustment necessity. The excess receipt from sales to the AE was classified as business income, not income from other sources. The Tribunal emphasized the requirement for detailed justification for adjustments under Section 80-IA(10), referencing the Tweezerman (India) case. Consequently, both the Revenue's appeal and the assessee's cross-objection were dismissed. Case-Laws Income Tax Tue, 18 Sep 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=219910