Tax Tribunal Deletes TPO Adjustments, Orders ALP Recomputation for Drug Pricing, and Rules on R&D Claims u/s 35(2AB).

ITAT ruled on multiple issues in a tax dispute. TPO adjustments regarding Northstar Health Care were deleted following prior precedent. For drug sales pricing adjustments, ALP recomputation was ordered. Provision for rebates written back was deleted based on statutory benefit principles. Addition for restructuring-related provisions was confirmed due to rate differential concerns. Job work charges addition was deleted as genuineness was established. For R&D deduction under s.35(2AB), claim denied due to missing Form 3CL but alternative relief under s.37/32 permitted subject to proper bifurcation. FCCB premium redemption expense disallowed under s.40(a)(i) for non-deduction of TDS, to be allowed in year when TDS is deducted. .....

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