https://www.taxtmi.com/caselaws?id=294239 The Tribunal partly allowed the assessee's appeals, directing recalculations and adjustments. The revenue's appeals were partly allowed or dismissed based on detailed analysis. Functional comparability, depreciation adjustments, and the assessee's bona fide belief in penalty proceedings were emphasized. The Tribunal upheld the reopening of assessments, allowed revenue expenditure for library books and software, excluded deferred revenue expenditure for transfer pricing, and directed the exclusion of depreciation from operating costs for PLI calculations. Comparable companies were included/excluded accordingly, and penalties under Section 271(1)(c) were deleted or to be re-examined for specific assessment years. en-us Mon, 01 May 2017 00:00:00 +0530 Wed, 31 Mar 2021 02:08:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=294239 The Tribunal partly allowed the assessee's appeals, directing recalculations and adjustments. The revenue's appeals were partly allowed or dismissed based on detailed analysis. Functional comparability, depreciation adjustments, and the assessee's bona fide belief in penalty proceedings were emphasized. The Tribunal upheld the reopening of assessments, allowed revenue expenditure for library books and software, excluded deferred revenue expenditure for transfer pricing, and directed the exclusion of depreciation from operating costs for PLI calculations. Comparable companies were included/excluded accordingly, and penalties under Section 271(1)(c) were deleted or to be re-examined for specific assessment years. Case-Laws Income Tax Mon, 01 May 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=294239