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The ITAT partly allowed the appeal of the assessee. The Tribunal restored transfer-pricing issues (grounds 4-11) to the file of the Ld. CIT(A) for reconsideration, holding that the CUP method's functional applicability required fresh scrutiny and could not be rejected summarily in favour of TNMM. The disallowance for interest on working-capital (grounds 12-12.2) was deleted and interest of Rs.17,57,358 allowed, the AO having taken an inconsistent stance vis-Ã -vis TPO findings. The CIT(A)'s direction to verify bad-debt admissibility was set aside. Miscellaneous expense disallowance (ground 14) was allowed; certain communication- and prior-period expense issues (grounds 15, 15.1 and 14-14.1) were remitted to the AO for verification.
The ITAT partly allowed the appeal of the assessee. The Tribunal restored transfer-pricing issues (grounds 4-11) to the file of the Ld. CIT(A) for reconsideration, holding that the CUP method's functional applicability required fresh scrutiny and could not be rejected summarily in favour of TNMM. The disallowance for interest on working-capital (grounds 12-12.2) was deleted and interest of Rs.17,57,358 allowed, the AO having taken an inconsistent stance vis-Ã -vis TPO findings. The CIT(A)'s direction to verify bad-debt admissibility was set aside. Miscellaneous expense disallowance (ground 14) was allowed; certain communication- and prior-period expense issues (grounds 15, 15.1 and 14-14.1) were remitted to the AO for verification.
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