https://www.taxtmi.com/caselaws?id=259984 The case involved the determination of the arm's length price of international transactions and the treatment of engineering service fees as capital or revenue expenditure. The Tribunal upheld the CIT(A)'s decision to delete the addition made by the Transfer Pricing Officer (TPO) for the international transactions, emphasizing the flawed comparability analysis. Additionally, the Tribunal affirmed the CIT(A)'s decision to treat the engineering service fees as revenue expenditure, dismissing the Revenue's appeal. The final order resulted in the dismissal of the Revenue's appeals for the assessment years 2005-06 and 2007-08, while allowing the assessee's appeal for the assessment year 2006-07. en-us Fri, 30 Jan 2015 00:00:00 +0530 Thu, 28 May 2015 06:34:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=259984 The case involved the determination of the arm's length price of international transactions and the treatment of engineering service fees as capital or revenue expenditure. The Tribunal upheld the CIT(A)'s decision to delete the addition made by the Transfer Pricing Officer (TPO) for the international transactions, emphasizing the flawed comparability analysis. Additionally, the Tribunal affirmed the CIT(A)'s decision to treat the engineering service fees as revenue expenditure, dismissing the Revenue's appeal. The final order resulted in the dismissal of the Revenue's appeals for the assessment years 2005-06 and 2007-08, while allowing the assessee's appeal for the assessment year 2006-07. Case-Laws Income Tax Fri, 30 Jan 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=259984