https://www.taxtmi.com/caselaws?id=259171 The Tribunal allowed the appeal in part, directing the TPO to reassess the ALP for management fee and license fee, consider other income as part of operating revenue, reevaluate selected comparables, and reconsider the deduction u/s 10A and depreciation rate for software license fee. The Tribunal also instructed the AO to review the refund adjustment and levy of interest u/s 234D, while dismissing the penalty proceedings under section 271(1)(c) as premature. Multiple issues were remanded for further examination, ensuring adherence to legal standards and precedents. en-us Fri, 17 Apr 2015 00:00:00 +0530 Mon, 26 Dec 2022 18:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=259171 The Tribunal allowed the appeal in part, directing the TPO to reassess the ALP for management fee and license fee, consider other income as part of operating revenue, reevaluate selected comparables, and reconsider the deduction u/s 10A and depreciation rate for software license fee. The Tribunal also instructed the AO to review the refund adjustment and levy of interest u/s 234D, while dismissing the penalty proceedings under section 271(1)(c) as premature. Multiple issues were remanded for further examination, ensuring adherence to legal standards and precedents. Case-Laws Income Tax Fri, 17 Apr 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=259171