https://www.taxtmi.com/caselaws?id=444474 The Tribunal partially allowed the appeal for statistical purposes, setting aside the transfer pricing adjustment issues to the AO/TPO for fresh benchmarking using either the Resale Price Method (RPM) or another method based on credible information. The Tribunal directed a reconsideration of the segmentation and margin computation, acknowledging the composite nature of the assessee's business activities and instructing the inclusion of foreign exchange fluctuation loss and liquidated damages as non-operating expenditures. The initiation of penalty proceedings under Section 271(1)(c) was deemed premature and dismissed. The Tribunal did not explicitly address the validity of the final assessment order, the principle of res-judicata, or the AIR mismatch addition. en-us Thu, 12 Oct 2023 00:00:00 +0530 Wed, 04 Dec 2024 14:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444474 The Tribunal partially allowed the appeal for statistical purposes, setting aside the transfer pricing adjustment issues to the AO/TPO for fresh benchmarking using either the Resale Price Method (RPM) or another method based on credible information. The Tribunal directed a reconsideration of the segmentation and margin computation, acknowledging the composite nature of the assessee's business activities and instructing the inclusion of foreign exchange fluctuation loss and liquidated damages as non-operating expenditures. The initiation of penalty proceedings under Section 271(1)(c) was deemed premature and dismissed. The Tribunal did not explicitly address the validity of the final assessment order, the principle of res-judicata, or the AIR mismatch addition. Case-Laws Income Tax Thu, 12 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444474