https://www.taxtmi.com/caselaws?id=294075 The Tribunal remanded various issues back to the Transfer Pricing Officer (TPO) for fresh adjudication, emphasizing the importance of correct functional profiles and comparables selection. The Tribunal directed the deletion of disallowed prior period expenses, upheld tax holiday benefits under Section 10A, and instructed the TPO to treat doubtful debts and donation expenses as non-operating. Consistency in transfer pricing adjustments across years was stressed, and penalty proceedings under Section 271(1)(c) were deemed premature. The Tribunal highlighted the necessity for a comprehensive and uniform approach in transfer pricing assessments. en-us Fri, 03 Aug 2018 00:00:00 +0530 Fri, 19 Mar 2021 11:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=294075 The Tribunal remanded various issues back to the Transfer Pricing Officer (TPO) for fresh adjudication, emphasizing the importance of correct functional profiles and comparables selection. The Tribunal directed the deletion of disallowed prior period expenses, upheld tax holiday benefits under Section 10A, and instructed the TPO to treat doubtful debts and donation expenses as non-operating. Consistency in transfer pricing adjustments across years was stressed, and penalty proceedings under Section 271(1)(c) were deemed premature. The Tribunal highlighted the necessity for a comprehensive and uniform approach in transfer pricing assessments. Case-Laws Income Tax Fri, 03 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=294075