https://www.taxtmi.com/caselaws?id=263397 The tribunal upheld the assessment order, dismissing the appeal and confirming the adjustments made by the Transfer Pricing Officer regarding the redetermination of the arm's length price of international transactions. The exclusion of Capital Trust Ltd. as a comparable company was upheld due to functional dissimilarity, emphasizing the importance of functional comparability over occasional losses. The tribunal found the initiation of penalty proceedings premature and disposed of the interest levy issue. Ultimately, the tribunal affirmed the assessment order, denying the requested adjustments and penalties. en-us Fri, 21 Aug 2015 00:00:00 +0530 Tue, 01 Sep 2015 16:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=263397 The tribunal upheld the assessment order, dismissing the appeal and confirming the adjustments made by the Transfer Pricing Officer regarding the redetermination of the arm's length price of international transactions. The exclusion of Capital Trust Ltd. as a comparable company was upheld due to functional dissimilarity, emphasizing the importance of functional comparability over occasional losses. The tribunal found the initiation of penalty proceedings premature and disposed of the interest levy issue. Ultimately, the tribunal affirmed the assessment order, denying the requested adjustments and penalties. Case-Laws Income Tax Fri, 21 Aug 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=263397