https://www.taxtmi.com/caselaws?id=191593 The Tribunal dismissed the challenge to the validity of reopening the assessment under Section 147 as not pressed. Regarding the Transfer Pricing Adjustment for advisory services to Associate Enterprises, the Tribunal accepted the assessee's methodology using TNMM and selected comparables, leading to a partial allowance of the appeal. The Tribunal excluded certain comparables and directed the TPO/AO to compute the arm's length price based on the final list of comparables, impacting the Transfer Pricing Adjustment. en-us Wed, 09 Mar 2016 00:00:00 +0530 Sat, 08 Apr 2017 09:48:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=191593 The Tribunal dismissed the challenge to the validity of reopening the assessment under Section 147 as not pressed. Regarding the Transfer Pricing Adjustment for advisory services to Associate Enterprises, the Tribunal accepted the assessee's methodology using TNMM and selected comparables, leading to a partial allowance of the appeal. The Tribunal excluded certain comparables and directed the TPO/AO to compute the arm's length price based on the final list of comparables, impacting the Transfer Pricing Adjustment. Case-Laws Income Tax Wed, 09 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=191593