https://www.taxtmi.com/caselaws?id=306280 The Tribunal partially allowed the Assessee's appeal, dismissing the revenue's appeal and directing the Transfer Pricing Officer to recalculate the Arm's Length Price. The Tribunal emphasized the significance of functional comparability and adherence to established precedents in Transfer Pricing assessments. The decision focused on the exclusion and inclusion of comparable companies, ultimately instructing the TPO to reconsider the ALP based on the Tribunal's directions and after providing the Assessee with an opportunity to be heard. en-us Wed, 03 Mar 2021 00:00:00 +0530 Fri, 20 Jan 2023 07:16:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306280 The Tribunal partially allowed the Assessee's appeal, dismissing the revenue's appeal and directing the Transfer Pricing Officer to recalculate the Arm's Length Price. The Tribunal emphasized the significance of functional comparability and adherence to established precedents in Transfer Pricing assessments. The decision focused on the exclusion and inclusion of comparable companies, ultimately instructing the TPO to reconsider the ALP based on the Tribunal's directions and after providing the Assessee with an opportunity to be heard. Case-Laws Income Tax Wed, 03 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306280