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The ITAT held that M/s Automotive Stamping Assemblies Ltd. and M/s Majestic Ltd. should be accepted as comparable entities for TP analysis under TNMM as they were initially selected and not persistent loss-making companies. M/s Spicer India Pvt. Ltd. was rightly included despite related party transactions as TNMM requires broad comparability. For M/s JBM Auto Ltd., the issue was restored to the AO/TPO to re-adjudicate after examining segmental information. Forex losses/gains were held operating in nature being linked to import transactions. Economic adjustments were denied as not granted earlier by the Tribunal. The forex loss disallowance u/s 43A was restored to the AO for fresh adjudication based on bifurcation of capital and revenue components. The additional depreciation claim was dismissed as not claimed originally and being revenue neutral.
The ITAT held that M/s Automotive Stamping Assemblies Ltd. and M/s Majestic Ltd. should be accepted as comparable entities for TP analysis under TNMM as they were initially selected and not persistent loss-making companies. M/s Spicer India Pvt. Ltd. was rightly included despite related party transactions as TNMM requires broad comparability. For M/s JBM Auto Ltd., the issue was restored to the AO/TPO to re-adjudicate after examining segmental information. Forex losses/gains were held operating in nature being linked to import transactions. Economic adjustments were denied as not granted earlier by the Tribunal. The forex loss disallowance u/s 43A was restored to the AO for fresh adjudication based on bifurcation of capital and revenue components. The additional depreciation claim was dismissed as not claimed originally and being revenue neutral.
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