Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The ITAT upheld that the TPO's order implementing the DRP's directions is an internal procedural act, not requiring electronic visibility or independent appeal. The AO's assessment was quashed for non-compliance with DRP directions, specifically for incorrectly treating the cost of steam as nil and making excessive ALP adjustments contrary to section 144C(13). The Tribunal deleted upward adjustments on electricity sales made by AO/TPO and DRP, accepting the CUP method for valuation. The DRP's direction to nullify the section 80IA deduction on steam transfer was set aside, allowing the assessee's claim based on expert evidence and proper benchmarking. Deduction under section 35(2AB) was denied for lack of prescribed Form 3CL, but allowed under sections 35(1)(i) and 35(1)(iv). Issues regarding double disallowance of RoU depreciation, amortized loan processing fees, and computational errors were remitted to AO for factual verification and appropriate relief.
The ITAT upheld that the TPO's order implementing the DRP's directions is an internal procedural act, not requiring electronic visibility or independent appeal. The AO's assessment was quashed for non-compliance with DRP directions, specifically for incorrectly treating the cost of steam as nil and making excessive ALP adjustments contrary to section 144C(13). The Tribunal deleted upward adjustments on electricity sales made by AO/TPO and DRP, accepting the CUP method for valuation. The DRP's direction to nullify the section 80IA deduction on steam transfer was set aside, allowing the assessee's claim based on expert evidence and proper benchmarking. Deduction under section 35(2AB) was denied for lack of prescribed Form 3CL, but allowed under sections 35(1)(i) and 35(1)(iv). Issues regarding double disallowance of RoU depreciation, amortized loan processing fees, and computational errors were remitted to AO for factual verification and appropriate relief.
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