https://www.taxtmi.com/caselaws?id=381161 The Tribunal allowed the appeal for statistical purposes, remanding key issues back to the AO/TPO for fresh determination. It emphasized the proper application of the Comparable Uncontrolled Price (CUP) method and consideration of relevant agreements and evidence in determining the Arm's Length Price (ALP) and imputing interest on outstanding receivables. The Tribunal directed a reconsideration of the issues related to addition to income on account of R&D and management cost sharing, aggregation approach, and imputation of interest on inter-company receivables. en-us Fri, 31 May 2019 00:00:00 +0530 Tue, 04 Jun 2019 17:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=381161 The Tribunal allowed the appeal for statistical purposes, remanding key issues back to the AO/TPO for fresh determination. It emphasized the proper application of the Comparable Uncontrolled Price (CUP) method and consideration of relevant agreements and evidence in determining the Arm's Length Price (ALP) and imputing interest on outstanding receivables. The Tribunal directed a reconsideration of the issues related to addition to income on account of R&D and management cost sharing, aggregation approach, and imputation of interest on inter-company receivables. Case-Laws Income Tax Fri, 31 May 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=381161