Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
ITAT followed its earlier orders in the assessee's own case and applied the same transfer pricing treatment for the year under appeal. For the ITES segment, it treated the benchmarking issue as covered by precedent and allowed the assessee's challenge to the arm's length price adjustment. For receivables from associated enterprises, it directed that delayed amounts beyond 90 days be benchmarked using 3 months' average Euribor plus 200 basis points, rather than sustaining the adjustment. For imported fixed assets, it held that a nil value could not be adopted and accepted the customs-determined value as the fair value, setting aside the transfer pricing adjustment.
ITAT followed its earlier orders in the assessee's own case and applied the same transfer pricing treatment for the year under appeal. For the ITES segment, it treated the benchmarking issue as covered by precedent and allowed the assessee's challenge to the arm's length price adjustment. For receivables from associated enterprises, it directed that delayed amounts beyond 90 days be benchmarked using 3 months' average Euribor plus 200 basis points, rather than sustaining the adjustment. For imported fixed assets, it held that a nil value could not be adopted and accepted the customs-determined value as the fair value, setting aside the transfer pricing adjustment.
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