https://www.taxtmi.com/caselaws?id=433833 The Tribunal partially allowed the appeal, directing re-examination of additional evidence and reassessment of disallowances based on guidelines provided. The Transfer Pricing Officer's adjustments on import and export transactions were to be recalculated considering a safe harbor/tolerance range. The Assessing Officer was instructed to verify if the assessee's own funds exceeded investments and if investments were old to justify no interest disallowance. The disallowance of interest converted into loans under Section 43B was upheld due to insufficient evidence. en-us Wed, 08 Feb 2023 00:00:00 +0530 Fri, 10 Feb 2023 09:44:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433833 The Tribunal partially allowed the appeal, directing re-examination of additional evidence and reassessment of disallowances based on guidelines provided. The Transfer Pricing Officer's adjustments on import and export transactions were to be recalculated considering a safe harbor/tolerance range. The Assessing Officer was instructed to verify if the assessee's own funds exceeded investments and if investments were old to justify no interest disallowance. The disallowance of interest converted into loans under Section 43B was upheld due to insufficient evidence. Case-Laws Income Tax Wed, 08 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433833