https://www.taxtmi.com/caselaws?id=286027 The Tribunal partly allowed the appeal, upholding the legality of the assessment and reference to the Transfer Pricing Officer (TPO). It rejected the assessee's claim regarding the motive of shifting profits and upheld the TPO's adjustments. The Tribunal provided detailed analysis on the comparability analysis and determination of Arm's Length Price (ALP), directing reconsideration of specific comparables by the TPO. It supported the negative working capital adjustment but found no merit in risk adjustments. The Tribunal deleted the disallowance of commission expense and directed the grant of MAT credit set-off. Interest under section 234B was upheld, and penalty proceedings initiation was affirmed. Directions by the Dispute Resolution Panel were upheld where confirming the draft assessment order. en-us Wed, 27 Jun 2018 00:00:00 +0530 Mon, 10 Feb 2020 08:56:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=286027 The Tribunal partly allowed the appeal, upholding the legality of the assessment and reference to the Transfer Pricing Officer (TPO). It rejected the assessee's claim regarding the motive of shifting profits and upheld the TPO's adjustments. The Tribunal provided detailed analysis on the comparability analysis and determination of Arm's Length Price (ALP), directing reconsideration of specific comparables by the TPO. It supported the negative working capital adjustment but found no merit in risk adjustments. The Tribunal deleted the disallowance of commission expense and directed the grant of MAT credit set-off. Interest under section 234B was upheld, and penalty proceedings initiation was affirmed. Directions by the Dispute Resolution Panel were upheld where confirming the draft assessment order. Case-Laws Income Tax Wed, 27 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=286027