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ITAT allowed the assessee's appeal on multiple transfer pricing adjustments. The Tribunal ruled that reimbursements received at cost from Associated Enterprises require no mark-up, following the assessee's own precedent and OECD guidelines. Corporate guarantee fee was upheld at 0.25%. Adjustments related to inter-unit transfers for Technical Textile and Chemical & Polymer businesses were deleted, with the Tribunal preferring CUP method over TNMM. Issues regarding electricity transfers were remitted for rebenchmarking following Jindal Steel. Deduction under s.32AC was remitted for fresh consideration. Disallowance under s.14A was deleted following the assessee's precedents. Weighted deduction under s.35(2AB) was partially allowed for approved facilities. Depreciation on goodwill was allowed as an intangible asset, while inventory write-offs were disallowed.
ITAT allowed the assessee's appeal on multiple transfer pricing adjustments. The Tribunal ruled that reimbursements received at cost from Associated Enterprises require no mark-up, following the assessee's own precedent and OECD guidelines. Corporate guarantee fee was upheld at 0.25%. Adjustments related to inter-unit transfers for Technical Textile and Chemical & Polymer businesses were deleted, with the Tribunal preferring CUP method over TNMM. Issues regarding electricity transfers were remitted for rebenchmarking following Jindal Steel. Deduction under s.32AC was remitted for fresh consideration. Disallowance under s.14A was deleted following the assessee's precedents. Weighted deduction under s.35(2AB) was partially allowed for approved facilities. Depreciation on goodwill was allowed as an intangible asset, while inventory write-offs were disallowed.
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