https://www.taxtmi.com/caselaws?id=402129 The Tribunal partly allowed the appeal of the assessee, directing the AO/TPO to exclude certain companies from the list of comparables for transfer pricing adjustment. Additionally, the disallowance of leased line/data link charges under section 40(a)(ia) was overturned, as the Tribunal held that such payments did not fall under technical services subject to TDS. The Tribunal did not address the penalty proceedings under section 271(1)(c) in detail. The matter was remitted back to the AO/TPO for fresh determination of the assessee's Arms Length Price (A.L.P.). en-us Thu, 17 Dec 2020 00:00:00 +0530 Thu, 24 Dec 2020 11:23:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=402129 The Tribunal partly allowed the appeal of the assessee, directing the AO/TPO to exclude certain companies from the list of comparables for transfer pricing adjustment. Additionally, the disallowance of leased line/data link charges under section 40(a)(ia) was overturned, as the Tribunal held that such payments did not fall under technical services subject to TDS. The Tribunal did not address the penalty proceedings under section 271(1)(c) in detail. The matter was remitted back to the AO/TPO for fresh determination of the assessee's Arms Length Price (A.L.P.). Case-Laws Income Tax Thu, 17 Dec 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=402129