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The Appellate Tribunal ruled in favor of the assessee on the following issues: TP adjustment on international transactions for sale of goods, disallowance u/s 14A read with Rule 8D, and denial of deduction u/s 35(2)(ab). Regarding TP adjustment, the Tribunal held that since the assessee was bearing credit risk, market risk, and cost of bill discounting when selling directly to AAL, but these risks were shifted to the AE after selling through TCIPL, the TP adjustment was unjustified. On Section 14A disallowance, the Tribunal found no justification for the disallowance as the assessee had sufficient interest-free funds. Concerning Section 35(2)(ab) deduction, the Tribunal held that the assessee cannot be denied the deduction for failure to file Form 3CL, which is required to be submitted by DSIR, relying on judicial precedents. However, the AO can verify the actual expenditure incurred.
The Appellate Tribunal ruled in favor of the assessee on the following issues: TP adjustment on international transactions for sale of goods, disallowance u/s 14A read with Rule 8D, and denial of deduction u/s 35(2)(ab). Regarding TP adjustment, the Tribunal held that since the assessee was bearing credit risk, market risk, and cost of bill discounting when selling directly to AAL, but these risks were shifted to the AE after selling through TCIPL, the TP adjustment was unjustified. On Section 14A disallowance, the Tribunal found no justification for the disallowance as the assessee had sufficient interest-free funds. Concerning Section 35(2)(ab) deduction, the Tribunal held that the assessee cannot be denied the deduction for failure to file Form 3CL, which is required to be submitted by DSIR, relying on judicial precedents. However, the AO can verify the actual expenditure incurred.
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