https://www.taxtmi.com/caselaws?id=409914 The Tribunal partly allowed the appeal, remanding several issues to the AO/TPO for fresh examination based on precedents. The Transfer Pricing adjustments for the Certification Service and ITES segments were reconsidered, with specific directions on adjustments, comparables, and methodological aspects. The issue of revenue recognition method change was upheld as not bona fide. The matters of TDS credit denial and depreciation on foreign exchange loss were remanded for factual verification and re-examination. The Tribunal stressed the importance of consistent legal application and thorough factual assessment in its decision. en-us Thu, 11 Mar 2021 00:00:00 +0530 Mon, 19 Jul 2021 18:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=409914 The Tribunal partly allowed the appeal, remanding several issues to the AO/TPO for fresh examination based on precedents. The Transfer Pricing adjustments for the Certification Service and ITES segments were reconsidered, with specific directions on adjustments, comparables, and methodological aspects. The issue of revenue recognition method change was upheld as not bona fide. The matters of TDS credit denial and depreciation on foreign exchange loss were remanded for factual verification and re-examination. The Tribunal stressed the importance of consistent legal application and thorough factual assessment in its decision. Case-Laws Income Tax Thu, 11 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=409914