https://www.taxtmi.com/caselaws?id=306122 The appeal was partly allowed, with directions given regarding correct benchmarking of international transactions and exclusion of certain comparables. The Tribunal upheld the use of TNMM for benchmarking and directed the AO to verify operating profits for specific comparables. The depreciation claim on UPS was dismissed, and the importance of functional similarity in selecting comparables was emphasized. The judgment did not delve into levy of interest under Section 234B or penalty proceedings under Section 271(1)(c). en-us Wed, 24 Aug 2016 00:00:00 +0530 Wed, 11 Jan 2023 20:37:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306122 The appeal was partly allowed, with directions given regarding correct benchmarking of international transactions and exclusion of certain comparables. The Tribunal upheld the use of TNMM for benchmarking and directed the AO to verify operating profits for specific comparables. The depreciation claim on UPS was dismissed, and the importance of functional similarity in selecting comparables was emphasized. The judgment did not delve into levy of interest under Section 234B or penalty proceedings under Section 271(1)(c). Case-Laws Income Tax Wed, 24 Aug 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306122