https://www.taxtmi.com/caselaws?id=290059 The Tribunal allowed the taxpayer's appeal for statistical purposes, directing the exclusion of certain comparables due to functional dissimilarity and remitting the disallowance of deposits back to the AO for further evaluation. The Tribunal underscored the taxpayer's consistent business model and highlighted errors in the TPO's functional and economic analysis, particularly in treating low-end marketing support services as high-end. The Tribunal found the TPO's adjustments unsustainable and emphasized the need for accurate economic analysis in transfer pricing. Issues regarding interest under sections 234B & 234C and penalty proceedings under section 271(1)(c) were not the primary focus. en-us Thu, 28 Nov 2019 00:00:00 +0530 Thu, 14 Nov 2024 11:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=290059 The Tribunal allowed the taxpayer's appeal for statistical purposes, directing the exclusion of certain comparables due to functional dissimilarity and remitting the disallowance of deposits back to the AO for further evaluation. The Tribunal underscored the taxpayer's consistent business model and highlighted errors in the TPO's functional and economic analysis, particularly in treating low-end marketing support services as high-end. The Tribunal found the TPO's adjustments unsustainable and emphasized the need for accurate economic analysis in transfer pricing. Issues regarding interest under sections 234B & 234C and penalty proceedings under section 271(1)(c) were not the primary focus. Case-Laws Income Tax Thu, 28 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=290059