https://www.taxtmi.com/caselaws?id=189408 The Tribunal allowed both appeals for statistical purposes, directing the Assessing Officer/Transfer Pricing Officer to reexamine the issues concerning transfer pricing adjustments, risk adjustment, disallowances under Sections 10A and 40(a)(ia), and addition of reversal of provisions. The Tribunal emphasized the need for a fresh examination of comparables, consideration of risk adjustment based on the CAPM model, evaluation of ownership change impact on Section 10A deduction, verification of tax compliance by the recipient of interest payment, and review of the addition related to provisions reversal. en-us Mon, 07 Sep 2015 00:00:00 +0530 Tue, 10 Jan 2017 12:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=189408 The Tribunal allowed both appeals for statistical purposes, directing the Assessing Officer/Transfer Pricing Officer to reexamine the issues concerning transfer pricing adjustments, risk adjustment, disallowances under Sections 10A and 40(a)(ia), and addition of reversal of provisions. The Tribunal emphasized the need for a fresh examination of comparables, consideration of risk adjustment based on the CAPM model, evaluation of ownership change impact on Section 10A deduction, verification of tax compliance by the recipient of interest payment, and review of the addition related to provisions reversal. Case-Laws Income Tax Mon, 07 Sep 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=189408