https://www.taxtmi.com/caselaws?id=377332 The Tribunal partially allowed the assessee's appeal, ruling that the Transfer Pricing Officer's adjustment of Rs. 3,98,05,532 for royalty and technical know-how payments was unjustified and should be removed. The Tribunal upheld the use of the Transactional Net Margin Method for determining the Arm's Length Price, criticizing the TPO's arbitrary application of the Comparable Uncontrolled Price method without comparable data. The Tribunal deemed the issues concerning warranty expenses, interest withdrawal under section 234D, and penalty proceedings as consequential and did not delve into them specifically. en-us Mon, 25 Mar 2019 00:00:00 +0530 Wed, 27 Mar 2019 12:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=377332 The Tribunal partially allowed the assessee's appeal, ruling that the Transfer Pricing Officer's adjustment of Rs. 3,98,05,532 for royalty and technical know-how payments was unjustified and should be removed. The Tribunal upheld the use of the Transactional Net Margin Method for determining the Arm's Length Price, criticizing the TPO's arbitrary application of the Comparable Uncontrolled Price method without comparable data. The Tribunal deemed the issues concerning warranty expenses, interest withdrawal under section 234D, and penalty proceedings as consequential and did not delve into them specifically. Case-Laws Income Tax Mon, 25 Mar 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=377332