https://www.taxtmi.com/caselaws?id=200567 The appeal was partly allowed for statistical purposes. The Transfer Pricing (TP) documentation rejection was relieved, directing a reworking of margins. Adjustments on transactions with non-AEs were limited to AE transactions only. The computation of margins under TNMM and working capital adjustments were directed to be re-examined. Certain comparables were excluded or remitted for further examination. The appellant's margin was within ALP after adjustments, rendering the risk differences issue academic. The tribunal directed consideration of the proviso to Section 92C(2) for ALP adjustments. Deduction u/s. 10A was to be reexamined, and capitalization of license fees adjusted. Refund verification was directed. en-us Fri, 06 Jan 2017 00:00:00 +0530 Thu, 05 Apr 2018 08:20:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=200567 The appeal was partly allowed for statistical purposes. The Transfer Pricing (TP) documentation rejection was relieved, directing a reworking of margins. Adjustments on transactions with non-AEs were limited to AE transactions only. The computation of margins under TNMM and working capital adjustments were directed to be re-examined. Certain comparables were excluded or remitted for further examination. The appellant's margin was within ALP after adjustments, rendering the risk differences issue academic. The tribunal directed consideration of the proviso to Section 92C(2) for ALP adjustments. Deduction u/s. 10A was to be reexamined, and capitalization of license fees adjusted. Refund verification was directed. Case-Laws Income Tax Fri, 06 Jan 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=200567