https://www.taxtmi.com/caselaws?id=261954 The Tribunal upheld the assessee's use of Berry Ratio and rejected the TPO's re-characterization of service/commission transactions as trading transactions. It found the TPO's adjustments for location savings and intangibles unwarranted. The inclusion of FOB value in the cost base was deemed impermissible, leading to a remand for fresh examination. The appeal was partly allowed for statistical purposes. en-us Fri, 24 Jul 2015 00:00:00 +0530 Tue, 28 Jul 2015 06:55:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=261954 The Tribunal upheld the assessee's use of Berry Ratio and rejected the TPO's re-characterization of service/commission transactions as trading transactions. It found the TPO's adjustments for location savings and intangibles unwarranted. The inclusion of FOB value in the cost base was deemed impermissible, leading to a remand for fresh examination. The appeal was partly allowed for statistical purposes. Case-Laws Income Tax Fri, 24 Jul 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=261954