Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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The ITAT upheld the CIT(A)'s order, dismissing the Revenue's appeals. It held that a corporate guarantee given by the assessee for its AE, without incurring expenditure, does not constitute an international transaction under section 92B. Regarding transfer pricing adjustments on instant coffee supplied in multiple sizes, the Tribunal found the TPO's selective comparison of only two sizes arbitrary and accepted the assessee's explanation of comparable pricing across all sizes, negating profit shifting. On interest for delayed receivables from AEs, the ITAT concurred with the CIT(A) that no undue credit advantage existed, and no adjustment was warranted. Consequently, all additions proposed by the TPO were deleted, affirming the arm's length nature of the transactions.
The ITAT upheld the CIT(A)'s order, dismissing the Revenue's appeals. It held that a corporate guarantee given by the assessee for its AE, without incurring expenditure, does not constitute an international transaction under section 92B. Regarding transfer pricing adjustments on instant coffee supplied in multiple sizes, the Tribunal found the TPO's selective comparison of only two sizes arbitrary and accepted the assessee's explanation of comparable pricing across all sizes, negating profit shifting. On interest for delayed receivables from AEs, the ITAT concurred with the CIT(A) that no undue credit advantage existed, and no adjustment was warranted. Consequently, all additions proposed by the TPO were deleted, affirming the arm's length nature of the transactions.
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