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The ITAT upheld the taxpayer's appeals in part. Transfer pricing adjustments to AMP under the Bright Line/"intensity" approaches were held not permissible under Chapter X and both substantive and protective AMP adjustments were deleted. The royalty TP adjustment was deleted and the AO directed to remove the adjustment. The TP issue on business support services was remitted to the TPO with instructions to exclude one comparable and fresh benchmarking. CSR expenditures and royalty expenditures examined under s.37(1) were allowed. Provision for warranty was accepted as an ascertained liability and allowed. Disallowance of unrealized MTM losses was restored to the file for computation to avoid double taxation. The claim for lower DDT rate was rejected.
The ITAT upheld the taxpayer's appeals in part. Transfer pricing adjustments to AMP under the Bright Line/"intensity" approaches were held not permissible under Chapter X and both substantive and protective AMP adjustments were deleted. The royalty TP adjustment was deleted and the AO directed to remove the adjustment. The TP issue on business support services was remitted to the TPO with instructions to exclude one comparable and fresh benchmarking. CSR expenditures and royalty expenditures examined under s.37(1) were allowed. Provision for warranty was accepted as an ascertained liability and allowed. Disallowance of unrealized MTM losses was restored to the file for computation to avoid double taxation. The claim for lower DDT rate was rejected.
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