https://www.taxtmi.com/caselaws?id=459391 ITAT Mumbai restored the transfer pricing adjustment matter to AO for fresh consideration after finding TPO failed to properly evaluate assessee's economic adjustments for excess depreciation, foreign exchange fluctuation, and under-utilized capacity in TNMM benchmarking. The tribunal directed AO to reconsider these adjustments with adequate opportunity to assessee. Regarding penalty under section 271(1)(c), ITAT ordered deletion as the notice under section 274 was defective for not specifying whether penalty was for concealment or inaccurate particulars, following Bombay HC precedent. en-us Wed, 24 Jan 2024 00:00:00 +0530 Wed, 11 Dec 2024 18:57:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459391 ITAT Mumbai restored the transfer pricing adjustment matter to AO for fresh consideration after finding TPO failed to properly evaluate assessee's economic adjustments for excess depreciation, foreign exchange fluctuation, and under-utilized capacity in TNMM benchmarking. The tribunal directed AO to reconsider these adjustments with adequate opportunity to assessee. Regarding penalty under section 271(1)(c), ITAT ordered deletion as the notice under section 274 was defective for not specifying whether penalty was for concealment or inaccurate particulars, following Bombay HC precedent. Case-Laws Income Tax Wed, 24 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459391