https://www.taxtmi.com/caselaws?id=401784 The Tribunal partially allowed the appeal, remanding certain issues back to the TPO for verification and correct computation. It decided in favor of the appellant on various grounds, including the transfer pricing adjustment on AMP expenses and the trading segment. The Tribunal held that the AMP expenditure was not an international transaction and rejected the intensity-based approach. It directed the exclusion and inclusion of certain companies in the trading segment for comparability analysis. The Tribunal also found merit in the appellant's arguments regarding incorrect margin adjustment and proportionate adjustment, partially allowing them for statistical purposes. The relief under Section 92C (2), interest under Section 234B, and penalty under Section 271(1)(c) were not adjudicated as they were deemed consequential. en-us Mon, 14 Dec 2020 00:00:00 +0530 Wed, 16 Dec 2020 20:47:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=401784 The Tribunal partially allowed the appeal, remanding certain issues back to the TPO for verification and correct computation. It decided in favor of the appellant on various grounds, including the transfer pricing adjustment on AMP expenses and the trading segment. The Tribunal held that the AMP expenditure was not an international transaction and rejected the intensity-based approach. It directed the exclusion and inclusion of certain companies in the trading segment for comparability analysis. The Tribunal also found merit in the appellant's arguments regarding incorrect margin adjustment and proportionate adjustment, partially allowing them for statistical purposes. The relief under Section 92C (2), interest under Section 234B, and penalty under Section 271(1)(c) were not adjudicated as they were deemed consequential. Case-Laws Income Tax Mon, 14 Dec 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=401784