https://www.taxtmi.com/caselaws?id=220204 The Tribunal partly allowed both appeals for statistical purposes, remanding key issues back to the AO for further verification and consideration. In the case involving Transfer Pricing Adjustment for Assessment Year 2003-04, the Tribunal found the Comparable Uncontrolled Price (CUP) method appropriate but required verification of adjustments for marketing, research functions, and volume differences. Similarly, in the case of Transfer Pricing Adjustment for Assessment Year 2005-06, the Tribunal directed the AO to reexamine adjustments for similar factors. Disallowances and interest charges were upheld in both cases, with the Tribunal emphasizing the need for thorough verification by the AO. en-us Fri, 14 Sep 2012 00:00:00 +0530 Mon, 17 Dec 2012 15:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=220204 The Tribunal partly allowed both appeals for statistical purposes, remanding key issues back to the AO for further verification and consideration. In the case involving Transfer Pricing Adjustment for Assessment Year 2003-04, the Tribunal found the Comparable Uncontrolled Price (CUP) method appropriate but required verification of adjustments for marketing, research functions, and volume differences. Similarly, in the case of Transfer Pricing Adjustment for Assessment Year 2005-06, the Tribunal directed the AO to reexamine adjustments for similar factors. Disallowances and interest charges were upheld in both cases, with the Tribunal emphasizing the need for thorough verification by the AO. Case-Laws Income Tax Fri, 14 Sep 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=220204