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ITAT dismissed grounds 1 and 2 regarding validity of assessment order, relying on Aztec Software precedent. The Tribunal allowed ground 3 concerning Intra Group Services, following a coordinate Bench decision in assessee's own case for AY 2010-11, as Revenue failed to demonstrate distinguishing features in the current assessment year. Similarly, ground 4 regarding disallowance of mark-up charged by AEs on fixed asset purchases was allowed, directing deletion of the ALP adjustment. Regarding royalty payments, ITAT rejected Revenue's appeal, citing EKL Appliances which negated the need-benefit test, and Magneti Marelli Powertrain which established that TPO cannot segregate transactions already aggregated and benchmarked under TNMM to reduce their ALP to nil under CUP method.
ITAT dismissed grounds 1 and 2 regarding validity of assessment order, relying on Aztec Software precedent. The Tribunal allowed ground 3 concerning Intra Group Services, following a coordinate Bench decision in assessee's own case for AY 2010-11, as Revenue failed to demonstrate distinguishing features in the current assessment year. Similarly, ground 4 regarding disallowance of mark-up charged by AEs on fixed asset purchases was allowed, directing deletion of the ALP adjustment. Regarding royalty payments, ITAT rejected Revenue's appeal, citing EKL Appliances which negated the need-benefit test, and Magneti Marelli Powertrain which established that TPO cannot segregate transactions already aggregated and benchmarked under TNMM to reduce their ALP to nil under CUP method.
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