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The ITAT remanded the transfer pricing adjustments related to marketing service fees, directing the TPO to accept the assessee's application of the TNMM method considering foreign AEs after verifying additional evidence. The upward interest adjustment on trade receivables from AEs was deleted, as the assessee did not charge interest on delayed payments from both AEs and non-AEs. Regarding corporate guarantee fees, the adjustment was restricted to 0.5% on the utilized amount of AED 3.1 million, not the sanctioned AED 11 million. The depreciation disallowance on ATM machines was set aside, allowing 40% as claimed. The gratuity deduction disallowance was reversed, permitting the deduction. Bad debts written off were accepted as irrecoverable per settled law. Claims of additional losses and ATM site rent charges were remitted to the AO for verification and appropriate decision in accordance with law.
The ITAT remanded the transfer pricing adjustments related to marketing service fees, directing the TPO to accept the assessee's application of the TNMM method considering foreign AEs after verifying additional evidence. The upward interest adjustment on trade receivables from AEs was deleted, as the assessee did not charge interest on delayed payments from both AEs and non-AEs. Regarding corporate guarantee fees, the adjustment was restricted to 0.5% on the utilized amount of AED 3.1 million, not the sanctioned AED 11 million. The depreciation disallowance on ATM machines was set aside, allowing 40% as claimed. The gratuity deduction disallowance was reversed, permitting the deduction. Bad debts written off were accepted as irrecoverable per settled law. Claims of additional losses and ATM site rent charges were remitted to the AO for verification and appropriate decision in accordance with law.
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