https://www.taxtmi.com/caselaws?id=260107 The appellant contested a transfer pricing adjustment by tax authorities, arguing against income enhancement based on alleged non-compliance with the arm's length principle. Disputes included the inclusion of goods value in profit margin computation, rejection of benchmarking approach, and disregard of detailed submissions on functional profile and international precedents. The appellant challenged penalty proceedings under Income Tax Act sections 271(1)(c) and 274, referencing a Delhi High Court ruling on commission-based remuneration. Ultimately, the appellant sought to establish errors in the authorities' assessment and penalty imposition, emphasizing compliance with international precedents and operational structure. en-us Wed, 08 Apr 2015 00:00:00 +0530 Sat, 05 Mar 2016 17:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=260107 The appellant contested a transfer pricing adjustment by tax authorities, arguing against income enhancement based on alleged non-compliance with the arm's length principle. Disputes included the inclusion of goods value in profit margin computation, rejection of benchmarking approach, and disregard of detailed submissions on functional profile and international precedents. The appellant challenged penalty proceedings under Income Tax Act sections 271(1)(c) and 274, referencing a Delhi High Court ruling on commission-based remuneration. Ultimately, the appellant sought to establish errors in the authorities' assessment and penalty imposition, emphasizing compliance with international precedents and operational structure. Case-Laws Income Tax Wed, 08 Apr 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=260107