https://www.taxtmi.com/caselaws?id=344451 The Tribunal allowed the appeal of the assessee, concluding that the adjustment of Rs. 7,21,92,932 to the Arm's Length Price was not justified. The Tribunal found that the recovery of expenses and sale of call manager phones should be excluded from the total cost for ALP determination. It upheld the use of contemporaneous data for determining ALP and addressed the exclusion and inclusion of comparables based on various grounds. The Tribunal rejected the assessee's request for adjustments related to sales and marketing efforts, ultimately determining that the price charged by the assessee fell within the permitted range, requiring no adjustment to the ALP. en-us Fri, 02 Jun 2017 00:00:00 +0530 Sat, 17 Jun 2017 11:07:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=344451 The Tribunal allowed the appeal of the assessee, concluding that the adjustment of Rs. 7,21,92,932 to the Arm's Length Price was not justified. The Tribunal found that the recovery of expenses and sale of call manager phones should be excluded from the total cost for ALP determination. It upheld the use of contemporaneous data for determining ALP and addressed the exclusion and inclusion of comparables based on various grounds. The Tribunal rejected the assessee's request for adjustments related to sales and marketing efforts, ultimately determining that the price charged by the assessee fell within the permitted range, requiring no adjustment to the ALP. Case-Laws Income Tax Fri, 02 Jun 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=344451