https://www.taxtmi.com/caselaws?id=427508 The Tribunal remanded the assessment to the Ld. TPO for a fresh determination, emphasizing the need for procedural fairness, accurate comparability analysis, and compliance with regulatory directives in transfer pricing assessments. The errors highlighted included the mischaracterization of services, defective comparability analysis, improper adjustments, incorrect inclusion/exclusion of comparables, wrong margin computation, and failure to allow working capital adjustment. The Tribunal stressed the importance of granting the appellant a proper opportunity to be heard and ensuring a fair computation of arms length for transfer pricing purposes. en-us Tue, 02 Aug 2022 00:00:00 +0530 Sat, 10 Sep 2022 07:03:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=427508 The Tribunal remanded the assessment to the Ld. TPO for a fresh determination, emphasizing the need for procedural fairness, accurate comparability analysis, and compliance with regulatory directives in transfer pricing assessments. The errors highlighted included the mischaracterization of services, defective comparability analysis, improper adjustments, incorrect inclusion/exclusion of comparables, wrong margin computation, and failure to allow working capital adjustment. The Tribunal stressed the importance of granting the appellant a proper opportunity to be heard and ensuring a fair computation of arms length for transfer pricing purposes. Case-Laws Income Tax Tue, 02 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=427508