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The ITAT set aside the impugned transfer-pricing adjustments and directed deletion of: (a) the TP adjustment premised on application of the Berry ratio and improperly selected comparables, holding the assessee's transactions with AEs to be at arm's length and that OP/OC (or GP margin/COP) would be the appropriate PLI if TNMM were applied; (b) notional interest on outstanding receivables, finding uniform commercial credit terms and accepted industry practice negated recharacterisation as interest-free loans; (c) addition under s.36(1)(va) for delayed PF payment, on facts showing timely compliance; (d) tax under s.115QA in relation to a share buy-back, on reliance upon prevailing public disclosures; and (e) unexplained expenditure treated on a "dumb document" basis. All challenged grounds allowed.
The ITAT set aside the impugned transfer-pricing adjustments and directed deletion of: (a) the TP adjustment premised on application of the Berry ratio and improperly selected comparables, holding the assessee's transactions with AEs to be at arm's length and that OP/OC (or GP margin/COP) would be the appropriate PLI if TNMM were applied; (b) notional interest on outstanding receivables, finding uniform commercial credit terms and accepted industry practice negated recharacterisation as interest-free loans; (c) addition under s.36(1)(va) for delayed PF payment, on facts showing timely compliance; (d) tax under s.115QA in relation to a share buy-back, on reliance upon prevailing public disclosures; and (e) unexplained expenditure treated on a "dumb document" basis. All challenged grounds allowed.
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