https://www.taxtmi.com/caselaws?id=380972 The Tribunal allowed the appeal, directing the exclusion of certain comparables due to functional dissimilarity with the assessee and restoring the issue of benchmarking the international transaction for the purchase of fixed assets back to the Transfer Pricing Officer for determination based on FAR analysis and contemporaneous documents filed by the assessee. The Tribunal found that the assessee's back-office support services were distinct from the comparables' high-end integrated services or high brand value, impacting profitability. The penalty and interest issues were deemed premature or consequential and not addressed. en-us Wed, 29 May 2019 00:00:00 +0530 Sat, 01 Jun 2019 07:56:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=380972 The Tribunal allowed the appeal, directing the exclusion of certain comparables due to functional dissimilarity with the assessee and restoring the issue of benchmarking the international transaction for the purchase of fixed assets back to the Transfer Pricing Officer for determination based on FAR analysis and contemporaneous documents filed by the assessee. The Tribunal found that the assessee's back-office support services were distinct from the comparables' high-end integrated services or high brand value, impacting profitability. The penalty and interest issues were deemed premature or consequential and not addressed. Case-Laws Income Tax Wed, 29 May 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=380972