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The ITAT directed exclusion of MPS, Manipal, Integra, and Wizard from the final comparable set for TP adjustment in ITES services, while including Bhilwara and UBM for marketing support services, with recomputation accordingly. For engineering services, the AO/TPO was instructed to follow the Tribunal's earlier order for AY 2017-18. In the manufacturing segment, the Tribunal accepted the assessee's economic adjustments under Rule 10B(1)(e) for low capacity utilization, remanding for appropriate margin adjustments and evidence submission. No disallowance under section 14A was warranted as no exempt income arose during the year. The addition under section 36(1)(va) for delayed employee contributions was upheld. The disallowance under section 40(a)(i) relating to TDS on salary paid to a foreign employee was set aside, as salary payments were covered under section 40(a)(iii) and appropriate tax was deducted under section 192, not section 195.
The ITAT directed exclusion of MPS, Manipal, Integra, and Wizard from the final comparable set for TP adjustment in ITES services, while including Bhilwara and UBM for marketing support services, with recomputation accordingly. For engineering services, the AO/TPO was instructed to follow the Tribunal's earlier order for AY 2017-18. In the manufacturing segment, the Tribunal accepted the assessee's economic adjustments under Rule 10B(1)(e) for low capacity utilization, remanding for appropriate margin adjustments and evidence submission. No disallowance under section 14A was warranted as no exempt income arose during the year. The addition under section 36(1)(va) for delayed employee contributions was upheld. The disallowance under section 40(a)(i) relating to TDS on salary paid to a foreign employee was set aside, as salary payments were covered under section 40(a)(iii) and appropriate tax was deducted under section 192, not section 195.
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