https://www.taxtmi.com/caselaws?id=312925 The Tribunal held that a jurisdictional challenge to a faceless assessment under section 144B was not sustainable. On transfer pricing, it ruled that ESOP cost could enter operating cost only if the assessee actually incurred the expenditure, and remitted the issue for verification of the scheme and financials. It applied turnover and functional comparability filters to exclude materially dissimilar companies, while remanding some comparables for fresh examination. Working capital adjustment was allowed to neutralise differences between the assessee and retained comparables; risk adjustment was left open subject to evidence, and interest under section 234B was treated as consequential. en-us Wed, 11 Jan 2023 00:00:00 +0530 Fri, 15 Mar 2024 06:53:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312925 The Tribunal held that a jurisdictional challenge to a faceless assessment under section 144B was not sustainable. On transfer pricing, it ruled that ESOP cost could enter operating cost only if the assessee actually incurred the expenditure, and remitted the issue for verification of the scheme and financials. It applied turnover and functional comparability filters to exclude materially dissimilar companies, while remanding some comparables for fresh examination. Working capital adjustment was allowed to neutralise differences between the assessee and retained comparables; risk adjustment was left open subject to evidence, and interest under section 234B was treated as consequential. Case-Laws Income Tax Wed, 11 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312925