https://www.taxtmi.com/caselaws?id=252568 The Tribunal in this case addressed two main issues. Firstly, it directed the use of the Berry Ratio as the Profit Level Indicator and excluded costs borne by associated enterprises for the Arm's Length Price adjustment of Rs. 68,15,17,853. The matter was sent back for fresh adjudication. Secondly, the Tribunal deleted the disallowance of Rs. 102,17,16,483 under Section 40(a)(i) for payments to non-residents, emphasizing deduction parity with residents under the India-Japan DTAA non-discrimination clause. en-us Tue, 21 Oct 2014 00:00:00 +0530 Sat, 05 Mar 2016 18:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=252568 The Tribunal in this case addressed two main issues. Firstly, it directed the use of the Berry Ratio as the Profit Level Indicator and excluded costs borne by associated enterprises for the Arm's Length Price adjustment of Rs. 68,15,17,853. The matter was sent back for fresh adjudication. Secondly, the Tribunal deleted the disallowance of Rs. 102,17,16,483 under Section 40(a)(i) for payments to non-residents, emphasizing deduction parity with residents under the India-Japan DTAA non-discrimination clause. Case-Laws Income Tax Tue, 21 Oct 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=252568