https://www.taxtmi.com/caselaws?id=382959 The Tribunal partly allowed the appeal in ITA No.377/PUN/2014 and allowed the appeal in ITA No.378/PUN/2014 for statistical purposes. Various transfer pricing issues were remitted back to the Assessing Officer to apply legal propositions and consider Advance Pricing Agreements under the Income-tax Act. The Tribunal directed the exclusion and inclusion of specific comparable companies in different segments, emphasized the consideration of contemporaneous data, allowed a risk adjustment following a specific precedent, dismissed the interest levy issue as consequential, and deemed the penalty proceedings premature. The Assessing Officer was instructed to re-examine and decide the matters in line with the Tribunal's directions and relevant APAs. en-us Mon, 24 Jun 2019 00:00:00 +0530 Fri, 12 Jul 2019 13:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=382959 The Tribunal partly allowed the appeal in ITA No.377/PUN/2014 and allowed the appeal in ITA No.378/PUN/2014 for statistical purposes. Various transfer pricing issues were remitted back to the Assessing Officer to apply legal propositions and consider Advance Pricing Agreements under the Income-tax Act. The Tribunal directed the exclusion and inclusion of specific comparable companies in different segments, emphasized the consideration of contemporaneous data, allowed a risk adjustment following a specific precedent, dismissed the interest levy issue as consequential, and deemed the penalty proceedings premature. The Assessing Officer was instructed to re-examine and decide the matters in line with the Tribunal's directions and relevant APAs. Case-Laws Income Tax Mon, 24 Jun 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=382959