https://www.taxtmi.com/caselaws?id=294093 The Tribunal dismissed the Department's appeal and partially allowed the assessee's appeal for statistical purposes. It remitted several issues back to the TPO/Assessing Officer for re-evaluation, adhering to previous decisions and directions. The Tribunal affirmed that transfer pricing adjustments should apply solely to AE transactions, not at the entity level. Penalty proceedings under section 271(1)(c) were deemed premature and dismissed. Compliance with DRP directions was mandated, and the selection of comparable companies was ordered for reassessment. The Tribunal's decision emphasized consistency with prior rulings, ensuring a fair and accurate determination of transfer pricing and related adjustments. en-us Fri, 12 Oct 2018 00:00:00 +0530 Tue, 12 Nov 2024 14:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=294093 The Tribunal dismissed the Department's appeal and partially allowed the assessee's appeal for statistical purposes. It remitted several issues back to the TPO/Assessing Officer for re-evaluation, adhering to previous decisions and directions. The Tribunal affirmed that transfer pricing adjustments should apply solely to AE transactions, not at the entity level. Penalty proceedings under section 271(1)(c) were deemed premature and dismissed. Compliance with DRP directions was mandated, and the selection of comparable companies was ordered for reassessment. The Tribunal's decision emphasized consistency with prior rulings, ensuring a fair and accurate determination of transfer pricing and related adjustments. Case-Laws Income Tax Fri, 12 Oct 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=294093