https://www.taxtmi.com/caselaws?id=252605 The Tribunal partly allowed the appeal for statistical purposes, directing the AO to re-examine specific transfer pricing adjustments, re-characterization of foreign exchange gain, and reduction of communication charges from export turnover. The Tribunal also dismissed grounds related to the levy of interest under Sections 234B and 234C, as well as the initiation of penalty proceedings under Section 271(1)(c), deeming them consequential to the final income determination. The Tribunal emphasized the importance of considering functional differences and proper verification in selecting comparables. en-us Fri, 24 Oct 2014 00:00:00 +0530 Thu, 30 Oct 2014 06:19:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=252605 The Tribunal partly allowed the appeal for statistical purposes, directing the AO to re-examine specific transfer pricing adjustments, re-characterization of foreign exchange gain, and reduction of communication charges from export turnover. The Tribunal also dismissed grounds related to the levy of interest under Sections 234B and 234C, as well as the initiation of penalty proceedings under Section 271(1)(c), deeming them consequential to the final income determination. The Tribunal emphasized the importance of considering functional differences and proper verification in selecting comparables. Case-Laws Income Tax Fri, 24 Oct 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=252605