https://www.taxtmi.com/caselaws?id=198782 The Tribunal partially allowed the appeal of the assessee, directing the re-computation of transfer pricing adjustments related to various international transactions. It upheld the aggregation approach for benchmarking and instructed the TPO to re-calculate adjustments using the TNMM method with external comparables. The Tribunal also addressed issues such as inappropriate comparisons of profitability, allocation of expenses, and PLI calculation, guiding the TPO to make corrections accordingly. Additionally, proposed disallowances of certain expenses were either allowed or restricted, and penalty proceedings were deemed premature and dismissed. en-us Fri, 03 Mar 2017 00:00:00 +0530 Fri, 30 Sep 2022 19:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=198782 The Tribunal partially allowed the appeal of the assessee, directing the re-computation of transfer pricing adjustments related to various international transactions. It upheld the aggregation approach for benchmarking and instructed the TPO to re-calculate adjustments using the TNMM method with external comparables. The Tribunal also addressed issues such as inappropriate comparisons of profitability, allocation of expenses, and PLI calculation, guiding the TPO to make corrections accordingly. Additionally, proposed disallowances of certain expenses were either allowed or restricted, and penalty proceedings were deemed premature and dismissed. Case-Laws Income Tax Fri, 03 Mar 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=198782