The ITAT directed de novo verification by the AO/TPO of transfer pricing segmentation: the taxpayer must reconcile its segmental audit report with audited financial statements, disclose segmental revenues and explain employee-cost variances; grounds 2-5 are allowed for statistical purposes. For benchmarking trade receivables from foreign AEs, the Tribunal prescribed LIBOR + 200 bps and allowed a 60-day interest-free credit period. The s.14A disallowance of Rs.2,00,990 was deleted. CSR expenditures were held non-deductible under s.37(1) and the disallowance upheld. Claims of prior-period expenses and discrepancies vis-Ã -vis Form 26AS were remitted to the AO for factual verification. The limitation issue was reserved to the AO to be addressed in light of the pending SC determination.
The ITAT directed de novo verification by the AO/TPO of transfer pricing segmentation: the taxpayer must reconcile its segmental audit report with audited financial statements, disclose segmental revenues and explain employee-cost variances; grounds 2-5 are allowed for statistical purposes. For benchmarking trade receivables from foreign AEs, the Tribunal prescribed LIBOR + 200 bps and allowed a 60-day interest-free credit period. The s.14A disallowance of Rs.2,00,990 was deleted. CSR expenditures were held non-deductible under s.37(1) and the disallowance upheld. Claims of prior-period expenses and discrepancies vis-Ã -vis Form 26AS were remitted to the AO for factual verification. The limitation issue was reserved to the AO to be addressed in light of the pending SC determination.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
