https://www.taxtmi.com/caselaws?id=299940 The High Court remitted the case back to the ITAT for further scrutiny regarding the assessee's involvement in knowledge management systems and international transactions, emphasizing the need for a detailed examination. The Court also directed reevaluation by the ITAT on the notional interest attributed to the assessee and adjustment made by the TPO, with a reservation of judgment. Additionally, the Court considered the exclusion of relative comparables for ALP determination, accepting appeals from both parties and reserving judgment for further consideration. en-us Wed, 07 Feb 2018 00:00:00 +0530 Thu, 06 Jan 2022 07:10:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=299940 The High Court remitted the case back to the ITAT for further scrutiny regarding the assessee's involvement in knowledge management systems and international transactions, emphasizing the need for a detailed examination. The Court also directed reevaluation by the ITAT on the notional interest attributed to the assessee and adjustment made by the TPO, with a reservation of judgment. Additionally, the Court considered the exclusion of relative comparables for ALP determination, accepting appeals from both parties and reserving judgment for further consideration. Case-Laws Income Tax Wed, 07 Feb 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=299940