https://www.taxtmi.com/caselaws?id=373963 The Tribunal upheld several decisions of the Commissioner (Appeals) in a transfer pricing case involving issues such as benchmarking of international transactions, contract migration cost, guarantee fee, interest for extended credit period, deduction under Section 10A, depreciation on intangibles, disallowance under Section 40(a)(i), and set-off of unabsorbed losses. The Tribunal emphasized functional comparability and adherence to judicial precedents, directing the Assessing Officer/TPO to re-determine the arm's length price of international transactions with associated enterprises based on its observations. en-us Wed, 16 Jan 2019 00:00:00 +0530 Sat, 01 Aug 2026 13:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=373963 The Tribunal upheld several decisions of the Commissioner (Appeals) in a transfer pricing case involving issues such as benchmarking of international transactions, contract migration cost, guarantee fee, interest for extended credit period, deduction under Section 10A, depreciation on intangibles, disallowance under Section 40(a)(i), and set-off of unabsorbed losses. The Tribunal emphasized functional comparability and adherence to judicial precedents, directing the Assessing Officer/TPO to re-determine the arm's length price of international transactions with associated enterprises based on its observations. Case-Laws Income Tax Wed, 16 Jan 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=373963