https://www.taxtmi.com/caselaws?id=386297 The Tribunal allowed the assessee's appeal in part and dismissed the revenue's appeal. The Transfer Pricing (TP) adjustment related to Advertising, Marketing, and Promotion (AMP) expenses was deleted as they were not considered international transactions. Similarly, the TP adjustment concerning Research and Training (R&T) expenditure was deleted as the expenses were not deemed international transactions. The matter related to Intra Group Services was remanded back to the Transfer Pricing Officer for reconsideration. Provisions for meeting liabilities and depreciation on Colour Soluble Machines were allowed. Disallowances under Section 14A and adjustments while computing book profits under Section 115JB were upheld in favor of the assessee. Penalty proceedings under Section 271(1)(c) were deemed premature, and the levy of interest was considered consequential. en-us Wed, 28 Aug 2019 00:00:00 +0530 Thu, 26 Sep 2019 06:57:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=386297 The Tribunal allowed the assessee's appeal in part and dismissed the revenue's appeal. The Transfer Pricing (TP) adjustment related to Advertising, Marketing, and Promotion (AMP) expenses was deleted as they were not considered international transactions. Similarly, the TP adjustment concerning Research and Training (R&T) expenditure was deleted as the expenses were not deemed international transactions. The matter related to Intra Group Services was remanded back to the Transfer Pricing Officer for reconsideration. Provisions for meeting liabilities and depreciation on Colour Soluble Machines were allowed. Disallowances under Section 14A and adjustments while computing book profits under Section 115JB were upheld in favor of the assessee. Penalty proceedings under Section 271(1)(c) were deemed premature, and the levy of interest was considered consequential. Case-Laws Income Tax Wed, 28 Aug 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=386297