https://www.taxtmi.com/caselaws?id=414897 The tribunal dismissed the appeals filed by the assessee for assessment years 2012-13 and 2013-14. The tribunal upheld the findings of the Transfer Pricing Officer (TPO) and Dispute Resolution Panel (DRP) on all issues, including recharacterizing the assessee as a contract manufacturer, determining the arm's length value of management services as 'NIL', and disallowing grossed-up TDS on external commercial borrowings. The order was pronounced on 3rd November 2021. en-us Wed, 03 Nov 2021 00:00:00 +0530 Mon, 27 Jun 2022 15:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=414897 The tribunal dismissed the appeals filed by the assessee for assessment years 2012-13 and 2013-14. The tribunal upheld the findings of the Transfer Pricing Officer (TPO) and Dispute Resolution Panel (DRP) on all issues, including recharacterizing the assessee as a contract manufacturer, determining the arm's length value of management services as 'NIL', and disallowing grossed-up TDS on external commercial borrowings. The order was pronounced on 3rd November 2021. Case-Laws Income Tax Wed, 03 Nov 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=414897