https://www.taxtmi.com/caselaws?id=257949 The Tribunal partly allowed the appeal, directing the AO/TPO to recompute the Arm's Length Price (ALP) and deductions based on its guidelines. The Tribunal stressed the importance of thorough examination of functional comparability and proper inclusion of operating expenses in the Transfer Pricing (TP) analysis. The decision upheld fair and accurate assessment principles in transfer pricing and tax deductions, emphasizing the need for meticulous consideration of comparables and expenses. en-us Fri, 20 Mar 2015 00:00:00 +0530 Fri, 27 Mar 2015 05:40:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=257949 The Tribunal partly allowed the appeal, directing the AO/TPO to recompute the Arm's Length Price (ALP) and deductions based on its guidelines. The Tribunal stressed the importance of thorough examination of functional comparability and proper inclusion of operating expenses in the Transfer Pricing (TP) analysis. The decision upheld fair and accurate assessment principles in transfer pricing and tax deductions, emphasizing the need for meticulous consideration of comparables and expenses. Case-Laws Income Tax Fri, 20 Mar 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=257949