https://www.taxtmi.com/caselaws?id=438245 The Tribunal allowed the assessee's appeal, ruling that the transfer pricing adjustment made under the omitted clause of the Act should be deleted. The Tribunal found fault with the rejection of external comparables by the TPO and upheld the inclusion of an internal comparable JV agreement. The departmental appeal was dismissed as it was based on incorrect factual presumptions. The Tribunal held that the reference to the TPO was invalid due to the omitted clause, directing the deletion of additions made by the AO and dismissing the departmental appeal. en-us Mon, 22 May 2023 00:00:00 +0530 Fri, 26 May 2023 08:25:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=438245 The Tribunal allowed the assessee's appeal, ruling that the transfer pricing adjustment made under the omitted clause of the Act should be deleted. The Tribunal found fault with the rejection of external comparables by the TPO and upheld the inclusion of an internal comparable JV agreement. The departmental appeal was dismissed as it was based on incorrect factual presumptions. The Tribunal held that the reference to the TPO was invalid due to the omitted clause, directing the deletion of additions made by the AO and dismissing the departmental appeal. Case-Laws Income Tax Mon, 22 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=438245