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Provisions expressly mentioned in the judgment/order text.
The ITAT allowed the appeal in part and directed the TPO/AO to re-determine transfer pricing margins: export incentives (e.g., duty drawback, export incentives) and cash discount income are to be treated as operating revenue for the assessee and included in margin computations; miscellaneous expenses are operating in nature and must be included in operating expenses of comparables where applicable; for a specified comparable with audited segmental reporting, only the auto-component segment shall be used rather than entity-level results; three additional comparables identified by the assessee are to be included in the final comparable set. The ITAT remitted the matter for compliance consistent with these rulings.
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