https://www.taxtmi.com/caselaws?id=275333 The tribunal partly allowed the appeals of both the assessee and the revenue, directing the AO/TPO to recompute the arm's length price (ALP) and make necessary adjustments as per the tribunal's findings. The tribunal emphasized the use of Transactional Net Margin Method (TNMM), proper selection of comparables, and appropriate adjustments for working capital and risk. The tribunal upheld the decision to consider foreign exchange gains/losses as operating in nature and directed a reevaluation of comparable companies for transfer pricing purposes. en-us Fri, 24 Jun 2016 00:00:00 +0530 Fri, 28 Sep 2018 07:31:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=275333 The tribunal partly allowed the appeals of both the assessee and the revenue, directing the AO/TPO to recompute the arm's length price (ALP) and make necessary adjustments as per the tribunal's findings. The tribunal emphasized the use of Transactional Net Margin Method (TNMM), proper selection of comparables, and appropriate adjustments for working capital and risk. The tribunal upheld the decision to consider foreign exchange gains/losses as operating in nature and directed a reevaluation of comparable companies for transfer pricing purposes. Case-Laws Income Tax Fri, 24 Jun 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=275333