https://www.taxtmi.com/caselaws?id=400338 The Tribunal partially allowed the appeal, directing reassessment by the AO/TPO to consider correct transfer pricing principles and comparables. It emphasized accurate benchmarking, correcting transaction characterization, and ensuring compliance with legal precedents for proper tax computation. The Tribunal rejected the TPO's characterization of distribution fees as royalties, directed the use of internal comparables, and rectified errors in interest computation and TDS credit, dismissing premature penalty proceedings. Deductions for education cess were allowed based on relevant case law. en-us Mon, 12 Oct 2020 00:00:00 +0530 Wed, 04 Nov 2020 09:18:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=400338 The Tribunal partially allowed the appeal, directing reassessment by the AO/TPO to consider correct transfer pricing principles and comparables. It emphasized accurate benchmarking, correcting transaction characterization, and ensuring compliance with legal precedents for proper tax computation. The Tribunal rejected the TPO's characterization of distribution fees as royalties, directed the use of internal comparables, and rectified errors in interest computation and TDS credit, dismissing premature penalty proceedings. Deductions for education cess were allowed based on relevant case law. Case-Laws Income Tax Mon, 12 Oct 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=400338