https://www.taxtmi.com/caselaws?id=302751 The appeal by the assessee was partly allowed. The Tribunal directed a de novo consideration of transfer pricing analysis, emphasizing understanding the business model. The TNMM method was rendered infructuous due to this direction. The Tribunal also instructed reworking interest on receivables and disallowed disallowance under Section 14A where no exempt income was earned. The issue of TDS on software expenses was referred back to AO for examination. Deduction under Section 10AA was directed to be allowed on assessed income. The Tribunal's decision aimed to ensure accurate transfer pricing and tax computations aligned with the business model and legal precedents. en-us Tue, 16 Nov 2021 00:00:00 +0530 Wed, 15 Jun 2022 20:58:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=302751 The appeal by the assessee was partly allowed. The Tribunal directed a de novo consideration of transfer pricing analysis, emphasizing understanding the business model. The TNMM method was rendered infructuous due to this direction. The Tribunal also instructed reworking interest on receivables and disallowed disallowance under Section 14A where no exempt income was earned. The issue of TDS on software expenses was referred back to AO for examination. Deduction under Section 10AA was directed to be allowed on assessed income. The Tribunal's decision aimed to ensure accurate transfer pricing and tax computations aligned with the business model and legal precedents. Case-Laws Income Tax Tue, 16 Nov 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=302751