https://www.taxtmi.com/caselaws?id=409869 The Tribunal partly allowed the appeal, setting aside the transfer pricing addition under the Manufacturing activity segment and remitting the matter to the AO/TPO for re-computation as per directions. The Tribunal excluded BEML as a comparable due to its government status and upheld the inclusion of JCB India Limited, directing a reasonable adjustment to its profit margin. The issue of working capital adjustment was remitted for re-computation, and the transfer pricing adjustment was restricted to international transactions in the manufacturing segment. The Tribunal also allowed re-computation of losses to be carried forward based on the resultant transfer pricing adjustment. en-us Tue, 29 Jun 2021 00:00:00 +0530 Mon, 19 Jul 2021 10:23:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=409869 The Tribunal partly allowed the appeal, setting aside the transfer pricing addition under the Manufacturing activity segment and remitting the matter to the AO/TPO for re-computation as per directions. The Tribunal excluded BEML as a comparable due to its government status and upheld the inclusion of JCB India Limited, directing a reasonable adjustment to its profit margin. The issue of working capital adjustment was remitted for re-computation, and the transfer pricing adjustment was restricted to international transactions in the manufacturing segment. The Tribunal also allowed re-computation of losses to be carried forward based on the resultant transfer pricing adjustment. Case-Laws Income Tax Tue, 29 Jun 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=409869