https://www.taxtmi.com/caselaws?id=305953 The Tribunal partially allowed the assessee's appeals by deleting the ALP adjustment and disallowance of depreciation while rejecting the Revenue's appeal. The Tribunal maintained consistency with previous rulings, endorsing the TNMM method over CUP for benchmarking international transactions. Additionally, the Tribunal emphasized the TPO's restricted role in determining ALP without scrutinizing the necessity of services, leading to the rejection of penalty proceedings under section 271(1)(c) as premature. en-us Wed, 18 Dec 2019 00:00:00 +0530 Mon, 02 Jan 2023 08:34:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=305953 The Tribunal partially allowed the assessee's appeals by deleting the ALP adjustment and disallowance of depreciation while rejecting the Revenue's appeal. The Tribunal maintained consistency with previous rulings, endorsing the TNMM method over CUP for benchmarking international transactions. Additionally, the Tribunal emphasized the TPO's restricted role in determining ALP without scrutinizing the necessity of services, leading to the rejection of penalty proceedings under section 271(1)(c) as premature. Case-Laws Income Tax Wed, 18 Dec 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=305953