https://www.taxtmi.com/caselaws?id=287090 The Tribunal partly allowed the assessee's appeal in a transfer pricing case. The Tribunal emphasized the requirement for the Transfer Pricing Officer (TPO) to adhere to prescribed methods for determining the Arm's Length Price (ALP) and rejected arbitrary estimations. The TPO's adjustment of the ALP for technical know-how fees and markup on recovery of expenses were overturned by the Tribunal, citing the necessity for proper documentation and adherence to pass-through transaction principles. The inclusion/exclusion of comparables issue became irrelevant, and a minor disallowance under Section 40(a)(ia) was dismissed due to the assessee not pursuing it during the hearing. en-us Fri, 27 Sep 2019 00:00:00 +0530 Sat, 28 Mar 2020 10:05:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=287090 The Tribunal partly allowed the assessee's appeal in a transfer pricing case. The Tribunal emphasized the requirement for the Transfer Pricing Officer (TPO) to adhere to prescribed methods for determining the Arm's Length Price (ALP) and rejected arbitrary estimations. The TPO's adjustment of the ALP for technical know-how fees and markup on recovery of expenses were overturned by the Tribunal, citing the necessity for proper documentation and adherence to pass-through transaction principles. The inclusion/exclusion of comparables issue became irrelevant, and a minor disallowance under Section 40(a)(ia) was dismissed due to the assessee not pursuing it during the hearing. Case-Laws Income Tax Fri, 27 Sep 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=287090