https://www.taxtmi.com/caselaws?id=306085 The Tribunal partially allowed the appeal, directing the exclusion of certain comparables and inclusion of others based on functional comparability and judicial precedents. Emphasizing proper selection criteria and adherence to natural justice principles in transfer pricing assessments, the Tribunal found errors in the TPO's approach, including mischaracterization of services, lack of criteria in economic analysis, and failure to grant adjustments for factors like risk and working capital. The decision highlighted the importance of accurate ALP determination and fair treatment of taxpayers in transfer pricing disputes. en-us Mon, 10 May 2021 00:00:00 +0530 Mon, 09 Jan 2023 20:34:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306085 The Tribunal partially allowed the appeal, directing the exclusion of certain comparables and inclusion of others based on functional comparability and judicial precedents. Emphasizing proper selection criteria and adherence to natural justice principles in transfer pricing assessments, the Tribunal found errors in the TPO's approach, including mischaracterization of services, lack of criteria in economic analysis, and failure to grant adjustments for factors like risk and working capital. The decision highlighted the importance of accurate ALP determination and fair treatment of taxpayers in transfer pricing disputes. Case-Laws Income Tax Mon, 10 May 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306085