https://www.taxtmi.com/caselaws?id=308760 The appeal was partly allowed, with various transfer pricing adjustments contested by the appellant. The rejection of the Cost Plus Method in favor of the Transaction Net Margin Method was upheld, with specific directions given for adjustments relating to AE transactions, inclusion of export incentives, underutilization of manufacturing capacities, selection of comparables, margin computation errors, differences in functions and risks, and commission on guarantees. The Tribunal directed certain issues to be reconsidered by the AO/TPO or DRP in accordance with legal precedents and principles. en-us Fri, 05 Apr 2019 00:00:00 +0530 Wed, 19 Jul 2023 20:59:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=308760 The appeal was partly allowed, with various transfer pricing adjustments contested by the appellant. The rejection of the Cost Plus Method in favor of the Transaction Net Margin Method was upheld, with specific directions given for adjustments relating to AE transactions, inclusion of export incentives, underutilization of manufacturing capacities, selection of comparables, margin computation errors, differences in functions and risks, and commission on guarantees. The Tribunal directed certain issues to be reconsidered by the AO/TPO or DRP in accordance with legal precedents and principles. Case-Laws Income Tax Fri, 05 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=308760