https://www.taxtmi.com/caselaws?id=442082 The Tribunal partially allowed the appeal, remitting several issues back to the TPO/AO for further consideration. The upward adjustment for AMP expenses and royalty payments were deleted, emphasizing consistency and rejecting the Bright Line Test. The issues concerning R&D services, IT support services, export and import adjustments, mark-up of recovery and expenses, and allocation of expenses were sent back for a fresh comparability test and examination. The claim for education cess was dismissed as not pressed. The Tribunal remitted the DTAA benefit issue for fresh evaluation, allowing the assessee to present further submissions. en-us Thu, 20 Jul 2023 00:00:00 +0530 Wed, 31 Jan 2024 14:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=442082 The Tribunal partially allowed the appeal, remitting several issues back to the TPO/AO for further consideration. The upward adjustment for AMP expenses and royalty payments were deleted, emphasizing consistency and rejecting the Bright Line Test. The issues concerning R&D services, IT support services, export and import adjustments, mark-up of recovery and expenses, and allocation of expenses were sent back for a fresh comparability test and examination. The claim for education cess was dismissed as not pressed. The Tribunal remitted the DTAA benefit issue for fresh evaluation, allowing the assessee to present further submissions. Case-Laws Income Tax Thu, 20 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=442082