https://www.taxtmi.com/caselaws?id=368957 The Tribunal partly allowed the appeal by the assessee, directing the Transfer Pricing Officer to make adjustments following the Tribunal's rulings. The Tribunal emphasized consistency in applying principles for determining the Arm's Length Price (ALP) in international transactions, including selection of comparable companies, treatment of foreign exchange fluctuations, adjustments for capacity utilization and working capital, and limiting transfer pricing adjustments to Associated Enterprises (AEs) transactions only. The Tribunal also addressed issues related to disallowance of prior period expenses, provisions for various expenses, levy of interest under section 234B, and initiation of penalty proceedings under section 271(1)(c). en-us Fri, 12 Oct 2018 00:00:00 +0530 Tue, 16 Oct 2018 17:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=368957 The Tribunal partly allowed the appeal by the assessee, directing the Transfer Pricing Officer to make adjustments following the Tribunal's rulings. The Tribunal emphasized consistency in applying principles for determining the Arm's Length Price (ALP) in international transactions, including selection of comparable companies, treatment of foreign exchange fluctuations, adjustments for capacity utilization and working capital, and limiting transfer pricing adjustments to Associated Enterprises (AEs) transactions only. The Tribunal also addressed issues related to disallowance of prior period expenses, provisions for various expenses, levy of interest under section 234B, and initiation of penalty proceedings under section 271(1)(c). Case-Laws Income Tax Fri, 12 Oct 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=368957