https://www.taxtmi.com/caselaws?id=192728 The Tribunal held that the use of Berry Ratio as the Profit Level Indicator was appropriate, rejecting the Transfer Pricing Officer's objections in the case involving Mitsubishi Corporation India Pvt. Ltd. The matter was remitted for fresh adjudication. Disallowance under Section 40(a)(i) for payments to entities without Permanent Establishments in India was deleted, and relief was granted for payments to entities with PEs due to the non-discrimination clause in the India-Japan DTAA. The disallowance under Section 14A was deleted as no exempt income was earned. The appeal was allowed in part. en-us Thu, 30 Oct 2014 00:00:00 +0530 Thu, 15 Jun 2017 07:57:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=192728 The Tribunal held that the use of Berry Ratio as the Profit Level Indicator was appropriate, rejecting the Transfer Pricing Officer's objections in the case involving Mitsubishi Corporation India Pvt. Ltd. The matter was remitted for fresh adjudication. Disallowance under Section 40(a)(i) for payments to entities without Permanent Establishments in India was deleted, and relief was granted for payments to entities with PEs due to the non-discrimination clause in the India-Japan DTAA. The disallowance under Section 14A was deleted as no exempt income was earned. The appeal was allowed in part. Case-Laws Income Tax Thu, 30 Oct 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=192728