https://www.taxtmi.com/caselaws?id=447345 Transfer pricing adjustment for non-US international transactions was directed to be reconsidered on the same Mutual Agreement Procedure basis already accepted for the US transactions, as no material functional or risk distinction was shown. The Tribunal held that the MAP treatment could be followed for the non-US transactions as well and restored the matter to the Assessing Officer and Transfer Pricing Officer for fresh determination after giving the assessee a reasonable and sufficient opportunity of being heard. en-us Wed, 20 Dec 2023 00:00:00 +0530 Fri, 22 Dec 2023 15:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447345 Transfer pricing adjustment for non-US international transactions was directed to be reconsidered on the same Mutual Agreement Procedure basis already accepted for the US transactions, as no material functional or risk distinction was shown. The Tribunal held that the MAP treatment could be followed for the non-US transactions as well and restored the matter to the Assessing Officer and Transfer Pricing Officer for fresh determination after giving the assessee a reasonable and sufficient opportunity of being heard. Case-Laws Income Tax Wed, 20 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447345