https://www.taxtmi.com/caselaws?id=262089 The tribunal partially allowed the appeal, directing a fresh examination by the AO/TPO on determining the Arm's Length Price (ALP) by Resale Price Method (RPM). The tribunal instructed consideration of the AE as the tested party and the appropriateness of RPM. The issue of ALP by Transactional Net Margin Method (TNMM) was considered academic, allowing the assessee to raise contentions if RPM is rejected. The initiation of penalty proceedings under section 271(1)(c) was deemed consequential and not maintainable. The order was pronounced on 27th May, 2015. en-us Wed, 27 May 2015 00:00:00 +0530 Mon, 17 Aug 2015 17:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=262089 The tribunal partially allowed the appeal, directing a fresh examination by the AO/TPO on determining the Arm's Length Price (ALP) by Resale Price Method (RPM). The tribunal instructed consideration of the AE as the tested party and the appropriateness of RPM. The issue of ALP by Transactional Net Margin Method (TNMM) was considered academic, allowing the assessee to raise contentions if RPM is rejected. The initiation of penalty proceedings under section 271(1)(c) was deemed consequential and not maintainable. The order was pronounced on 27th May, 2015. Case-Laws Income Tax Wed, 27 May 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=262089