The ITAT ruled in favor of the assessee on multiple transfer ...

Tribunal Eliminates Transfer Pricing Adjustments After Excluding Non-Comparable Companies Under Section 92C

March 15, 2025

Case Laws Income Tax AT

The ITAT ruled in favor of the assessee on multiple transfer pricing issues. The Tribunal excluded comparables Tata Elexi and Sasken Technologies, bringing the appellant's margin (9.44%) within acceptable range (11.66% +/-3%), eliminating TP adjustment. Similarly, ADTL and TCG were excluded as comparables for CRDS services. The ITAT deleted TP adjustments for intra-group services and advertisement/marketing expenses, finding the latter not to be international transactions. Additional favorable rulings included: no SS14A disallowance where no exempt income was earned; deletion of duplicative SS41(1) addition for trading liability cessation; allowance of lease rental expenses for assets on financial lease; and confirmation that SS80G deduction for CSR contributions remains available despite Explanation 2 to SS37(1).

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The ITAT ruled in favor of the assessee on multiple transfer ...

Tribunal Eliminates Transfer Pricing Adjustments After Excluding Non-Comparable Companies Under Section 92C

March 15, 2025

Case Laws Income Tax AT

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