https://www.taxtmi.com/caselaws?id=354059 The Tribunal partly allowed the appeal, emphasizing the need for a proper application of mind in transfer pricing assessments. The Tribunal found flaws in the TPO's process, excluded certain comparables, and directed a net margin of 22.67% instead of 24%. Disallowances under sections 10A and 14A were partly allowed, with directions for reconsideration. The issue of levy of interest under section 234B was considered consequential, and the initiation of penalty proceedings under section 271(1)(c) was deemed premature. The Tribunal's decision stressed the importance of adherence to legal principles in transfer pricing and tax assessments. en-us Wed, 10 Jan 2018 00:00:00 +0530 Wed, 17 Jan 2018 12:02:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=354059 The Tribunal partly allowed the appeal, emphasizing the need for a proper application of mind in transfer pricing assessments. The Tribunal found flaws in the TPO's process, excluded certain comparables, and directed a net margin of 22.67% instead of 24%. Disallowances under sections 10A and 14A were partly allowed, with directions for reconsideration. The issue of levy of interest under section 234B was considered consequential, and the initiation of penalty proceedings under section 271(1)(c) was deemed premature. The Tribunal's decision stressed the importance of adherence to legal principles in transfer pricing and tax assessments. Case-Laws Income Tax Wed, 10 Jan 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=354059