Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
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The ITAT directed the AO to treat the excess consideration paid in slump sale transactions as goodwill and allow depreciation accordingly, following a coordinate bench's precedent. The tribunal allowed the set-off of brought forward unabsorbed depreciation, distinguishing it from business loss. Transfer Pricing adjustments on AMP expenses were disallowed due to lack of evidence of association or statutory basis for the Bright Line Test. The tribunal directed inclusion of Satyatej Commercial Co. Ltd. as a comparable for import of finished goods transactions, excluding freight costs. It also ordered exclusion of Hand Innovations Inc. and RG Medical Diagnostics for benchmarking indenting commission transactions based on product and territorial similarity. The tribunal held that reimbursement of expenses could not be valued at nil without independent comparable evidence and disallowed the TPO's and DRP's treatment, allowing the related appeal ground. All contested grounds raised by the assessee were allowed accordingly.
The ITAT directed the AO to treat the excess consideration paid in slump sale transactions as goodwill and allow depreciation accordingly, following a coordinate bench's precedent. The tribunal allowed the set-off of brought forward unabsorbed depreciation, distinguishing it from business loss. Transfer Pricing adjustments on AMP expenses were disallowed due to lack of evidence of association or statutory basis for the Bright Line Test. The tribunal directed inclusion of Satyatej Commercial Co. Ltd. as a comparable for import of finished goods transactions, excluding freight costs. It also ordered exclusion of Hand Innovations Inc. and RG Medical Diagnostics for benchmarking indenting commission transactions based on product and territorial similarity. The tribunal held that reimbursement of expenses could not be valued at nil without independent comparable evidence and disallowed the TPO's and DRP's treatment, allowing the related appeal ground. All contested grounds raised by the assessee were allowed accordingly.
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