https://www.taxtmi.com/caselaws?id=299612 The Tribunal partly allowed the appeal, directing the AO/TPO to reconsider and recompute various adjustments for Transfer Pricing in the Software Development and SIM Card Assembly Segments. Specific comparables were excluded and included based on functional comparability. Capacity and working capital adjustments were addressed, emphasizing adherence to legal principles. The Tribunal stressed restricting Transfer Pricing adjustments to international transactions and accurate computation of interest and tax credits. The decision highlighted the significance of precise benchmarking and consistency across segments. en-us Thu, 23 Aug 2018 00:00:00 +0530 Wed, 22 Dec 2021 20:35:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=299612 The Tribunal partly allowed the appeal, directing the AO/TPO to reconsider and recompute various adjustments for Transfer Pricing in the Software Development and SIM Card Assembly Segments. Specific comparables were excluded and included based on functional comparability. Capacity and working capital adjustments were addressed, emphasizing adherence to legal principles. The Tribunal stressed restricting Transfer Pricing adjustments to international transactions and accurate computation of interest and tax credits. The decision highlighted the significance of precise benchmarking and consistency across segments. Case-Laws Income Tax Thu, 23 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=299612