https://www.taxtmi.com/caselaws?id=308156 The Tribunal remanded the transfer pricing adjustments in the manufacturing segment for further verification, allowing adjustments for capacity utilization and requiring proper analysis of Forex fluctuations and impairment losses. The comparables analysis was also remanded for fresh examination. In the case of management fees, the Tribunal found procedural errors by the DRP and allowed grounds for statistical purposes. In the ITES segment, adjustments were partly allowed based on the inclusion/exclusion of comparables and working capital adjustments. The protective disallowance of management fees under Section 37 was remitted back for fresh examination. The appeal in IT(TP)A No.790/Bang/2019 was dismissed, while the appeal in IT(TP)A No.103/Bang/2019 was partly allowed. en-us Tue, 22 Mar 2022 00:00:00 +0530 Sun, 04 Jun 2023 19:47:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=308156 The Tribunal remanded the transfer pricing adjustments in the manufacturing segment for further verification, allowing adjustments for capacity utilization and requiring proper analysis of Forex fluctuations and impairment losses. The comparables analysis was also remanded for fresh examination. In the case of management fees, the Tribunal found procedural errors by the DRP and allowed grounds for statistical purposes. In the ITES segment, adjustments were partly allowed based on the inclusion/exclusion of comparables and working capital adjustments. The protective disallowance of management fees under Section 37 was remitted back for fresh examination. The appeal in IT(TP)A No.790/Bang/2019 was dismissed, while the appeal in IT(TP)A No.103/Bang/2019 was partly allowed. Case-Laws Income Tax Tue, 22 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=308156