https://www.taxtmi.com/caselaws?id=353251 The appeal was partly allowed in the case involving transfer pricing adjustments and international transactions. The Tribunal upheld the aggregation approach for benchmarking manufacturing activities, directed comparison of margins using TNMM method, and deemed TPO's profitability comparison inappropriate. The Tribunal also directed the adoption of "net profit to sales" as PLI, allowed the benefit of a 5% variation, and upheld disallowance of deductions under sections 80IB and 14A. Penalty proceedings initiation was not addressed. The decision favored the assessee based on precedents and detailed analysis, resulting in specific directions for benchmarking and disallowances. en-us Mon, 30 Oct 2017 00:00:00 +0530 Fri, 30 Sep 2022 18:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=353251 The appeal was partly allowed in the case involving transfer pricing adjustments and international transactions. The Tribunal upheld the aggregation approach for benchmarking manufacturing activities, directed comparison of margins using TNMM method, and deemed TPO's profitability comparison inappropriate. The Tribunal also directed the adoption of "net profit to sales" as PLI, allowed the benefit of a 5% variation, and upheld disallowance of deductions under sections 80IB and 14A. Penalty proceedings initiation was not addressed. The decision favored the assessee based on precedents and detailed analysis, resulting in specific directions for benchmarking and disallowances. Case-Laws Income Tax Mon, 30 Oct 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=353251