https://www.taxtmi.com/caselaws?id=374302 The appeal was partly allowed for statistical purposes, with significant issues remanded back to the Transfer Pricing Officer/Assessing Officer for reconsideration. The Tribunal emphasized consistency in segment treatment and accepted the appellant's arguments based on previous favorable rulings. The Transfer Pricing Adjustment issue was remanded for reconsideration based on Functional, Asset, and Risk analysis. Adjustment on account of Advance Billing and Business Promotion Expenses were allowed based on previous Tribunal decisions in the appellant's favor. The issue of Penalty Proceedings initiation was not elaborated upon in the judgment. en-us Mon, 28 Jan 2019 00:00:00 +0530 Wed, 30 Jan 2019 08:20:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=374302 The appeal was partly allowed for statistical purposes, with significant issues remanded back to the Transfer Pricing Officer/Assessing Officer for reconsideration. The Tribunal emphasized consistency in segment treatment and accepted the appellant's arguments based on previous favorable rulings. The Transfer Pricing Adjustment issue was remanded for reconsideration based on Functional, Asset, and Risk analysis. Adjustment on account of Advance Billing and Business Promotion Expenses were allowed based on previous Tribunal decisions in the appellant's favor. The issue of Penalty Proceedings initiation was not elaborated upon in the judgment. Case-Laws Income Tax Mon, 28 Jan 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=374302