https://www.taxtmi.com/caselaws?id=306221 The Tribunal allowed the assessee's appeal partly for statistical purposes, remanding the re-characterization issue to the Assessing Officer for a comprehensive review. The Tribunal criticized the Transfer Pricing Officer's reliance on a previous order without proper examination of the nature of the services provided. It highlighted inconsistencies in the re-characterization and directed a thorough assessment considering documentary evidence and past practices. The Tribunal emphasized the importance of a fair opportunity for the assessee to present its case, indicating a need for a detailed reassessment by the Assessing Officer. Other issues raised were considered academic but left open for future review if needed. en-us Wed, 24 Feb 2021 00:00:00 +0530 Tue, 17 Jan 2023 20:53:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306221 The Tribunal allowed the assessee's appeal partly for statistical purposes, remanding the re-characterization issue to the Assessing Officer for a comprehensive review. The Tribunal criticized the Transfer Pricing Officer's reliance on a previous order without proper examination of the nature of the services provided. It highlighted inconsistencies in the re-characterization and directed a thorough assessment considering documentary evidence and past practices. The Tribunal emphasized the importance of a fair opportunity for the assessee to present its case, indicating a need for a detailed reassessment by the Assessing Officer. Other issues raised were considered academic but left open for future review if needed. Case-Laws Income Tax Wed, 24 Feb 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306221