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The ITAT allowed the assessee's appeal, directing the AO to reconsider multiple transfer pricing and tax-related adjustments. Key holdings include: (1) deletion of TP adjustments in SWD and test/measurement equipment segments, (2) accepting the assessee's profit level indicator methodology, (3) setting interest rate at LIBOR + 200 basis points, (4) directing reassessment of CSR expenditure under section 80G, (5) remanding long-term capital gain computation for fresh hearing, and (6) instructing verification of TDS credit from merged entity. The tribunal comprehensively upheld the assessee's contentions, providing procedural relief and mandating detailed reconsideration by lower authorities.
The ITAT allowed the assessee's appeal, directing the AO to reconsider multiple transfer pricing and tax-related adjustments. Key holdings include: (1) deletion of TP adjustments in SWD and test/measurement equipment segments, (2) accepting the assessee's profit level indicator methodology, (3) setting interest rate at LIBOR + 200 basis points, (4) directing reassessment of CSR expenditure under section 80G, (5) remanding long-term capital gain computation for fresh hearing, and (6) instructing verification of TDS credit from merged entity. The tribunal comprehensively upheld the assessee's contentions, providing procedural relief and mandating detailed reconsideration by lower authorities.
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