https://www.taxtmi.com/caselaws?id=196444 The Tribunal allowed the appeal for statistical purposes, directing the AO/TPO to determine the Arm's Length Price (ALP) of the international transactions afresh in accordance with its directions. The Tribunal excluded certain comparables and set aside the inclusion/exclusion of others to the TPO for reconsideration based on additional evidence. Emphasizing the importance of functional analysis and comparability in Transfer Pricing cases, the Tribunal stressed adherence to Rule 10B(2) of the Income Tax Rules, 1962. en-us Fri, 22 Apr 2016 00:00:00 +0530 Fri, 01 Dec 2017 07:29:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=196444 The Tribunal allowed the appeal for statistical purposes, directing the AO/TPO to determine the Arm's Length Price (ALP) of the international transactions afresh in accordance with its directions. The Tribunal excluded certain comparables and set aside the inclusion/exclusion of others to the TPO for reconsideration based on additional evidence. Emphasizing the importance of functional analysis and comparability in Transfer Pricing cases, the Tribunal stressed adherence to Rule 10B(2) of the Income Tax Rules, 1962. Case-Laws Income Tax Fri, 22 Apr 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=196444