https://www.taxtmi.com/caselaws?id=255864 The Tribunal partly allowed the appeal of HSBC Electronic Data Processing India Private Limited, directing the Assessing Officer and Transfer Pricing Officer to re-examine certain issues. The Tribunal excluded certain companies as comparables due to extraordinary events or functional differences and directed reconsideration of risk adjustments. It instructed the AO to treat foreign exchange gain as business income, reduce communication charges from both export and total turnover, and dismissed the levy of interest under Section 234B as inconsequential. The decision provided directions for fresh proceedings with reasonable opportunities for the assessee to be heard. en-us Fri, 24 Oct 2014 00:00:00 +0530 Sun, 03 May 2015 11:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=255864 The Tribunal partly allowed the appeal of HSBC Electronic Data Processing India Private Limited, directing the Assessing Officer and Transfer Pricing Officer to re-examine certain issues. The Tribunal excluded certain companies as comparables due to extraordinary events or functional differences and directed reconsideration of risk adjustments. It instructed the AO to treat foreign exchange gain as business income, reduce communication charges from both export and total turnover, and dismissed the levy of interest under Section 234B as inconsequential. The decision provided directions for fresh proceedings with reasonable opportunities for the assessee to be heard. Case-Laws Income Tax Fri, 24 Oct 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=255864