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...
In transfer pricing benchmarking, the turnover filter and broad functional comparability were treated as relevant comparability criteria under TNMM. A diagnostics company was validly excluded because its turnover fell below the modified range, and earlier-year inclusion did not control since each year must be tested on its own facts. A separate glassware and laboratory-products company was also excluded because its product mix and customer profile were not broadly comparable to medical devices used in patient treatment. Subvention receipts under the distribution arrangement were held to reduce operating cost, not form part of operating revenue, so the assessee's operating margin was correctly taken at 5.04%.
In transfer pricing benchmarking, the turnover filter and broad functional comparability were treated as relevant comparability criteria under TNMM. A diagnostics company was validly excluded because its turnover fell below the modified range, and earlier-year inclusion did not control since each year must be tested on its own facts. A separate glassware and laboratory-products company was also excluded because its product mix and customer profile were not broadly comparable to medical devices used in patient treatment. Subvention receipts under the distribution arrangement were held to reduce operating cost, not form part of operating revenue, so the assessee's operating margin was correctly taken at 5.04%.
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