https://www.taxtmi.com/caselaws?id=289899 The ITAT partly allowed the appeal and Cross Objection, upholding the CIT(A)'s decision to exclude telecommunication expenses from both export and total turnover, aligning with the jurisdictional HC's ruling. It modified the CIT(A)'s direction on risk adjustment, instructing the TPO to consider it if relevant details are provided. The Tribunal ruled against the negative working capital adjustment, citing the lack of borrowed funds or working capital risk. The judgment emphasized consistency and adherence to established legal principles in transfer pricing adjustments. en-us Thu, 31 Mar 2016 00:00:00 +0530 Thu, 14 Nov 2024 11:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=289899 The ITAT partly allowed the appeal and Cross Objection, upholding the CIT(A)'s decision to exclude telecommunication expenses from both export and total turnover, aligning with the jurisdictional HC's ruling. It modified the CIT(A)'s direction on risk adjustment, instructing the TPO to consider it if relevant details are provided. The Tribunal ruled against the negative working capital adjustment, citing the lack of borrowed funds or working capital risk. The judgment emphasized consistency and adherence to established legal principles in transfer pricing adjustments. Case-Laws Income Tax Thu, 31 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=289899