https://www.taxtmi.com/caselaws?id=274030 The Tribunal remanded the matter to the DRP for passing a reasoned order, allowing the assessee a reasonable opportunity to be heard. The Tribunal upheld exclusions of certain companies as comparables for IT Enabled Services due to functional dissimilarities. It also directed the exclusion of a company from Marketing Support Services comparables due to significant related party transactions. The Tribunal rejected the assessee's argument for using Resale Price Method, upholding the use of Transactional Net Margin Method for distribution activities. The TPO was directed to recompute the Arm's Length Price for all segments, partly allowing the appeal. en-us Fri, 11 May 2018 00:00:00 +0530 Wed, 25 Jul 2018 13:25:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=274030 The Tribunal remanded the matter to the DRP for passing a reasoned order, allowing the assessee a reasonable opportunity to be heard. The Tribunal upheld exclusions of certain companies as comparables for IT Enabled Services due to functional dissimilarities. It also directed the exclusion of a company from Marketing Support Services comparables due to significant related party transactions. The Tribunal rejected the assessee's argument for using Resale Price Method, upholding the use of Transactional Net Margin Method for distribution activities. The TPO was directed to recompute the Arm's Length Price for all segments, partly allowing the appeal. Case-Laws Income Tax Fri, 11 May 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=274030