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        Case ID :
        Income Tax

        ITAT upholds that TP adjustments in respect of international...

        TP adjustments deleted; TNMM benchmark allowed; rectify s.115JB profits; credits and s.234C interest reviewed; 80G CSR allowed

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                ITAT upholds that TP adjustments in respect of international transactions for export of finished goods and royalty payments to an AE are deleted: ALP may be benchmarked by TNMM where CUP is inappropriate due to factual/geographical differences, following a co-ordinate bench decision in the assessee's own case. The tribunal directs rectification of an inadvertent addition of TP adjustments in the computation of book profit under s.115JB to align with the final order. Claims for credit under s.115JAA and TDS are remitted to the AO for verification and appropriate grant. Interest under s.234C is to be computed on returned income after accounting taxes paid. Deduction u/s.80G for donations from CSR funds is allowed where statutory conditions are satisfied.
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