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Appeal by assessee was partly allowed. ITAT held that separate TP benchmarking for royalty was unwarranted when TNMM was accepted for other international transactions; assessee's TNMM-based ALP for royalty was upheld. Exemption u/s 10AA and deduction u/s 80JJAA, disallowed by CPC for a return filed a few hours late due to portal glitches, were sustained as valid, the due-date condition not being applicable for A.Y. 2018-19. Disallowance u/s 14A as made by AO was upheld, but ITAT directed that such disallowance not be added while computing book profits u/s 115JB. Deduction u/s 35(2AB), correction of double taxation of LTCG, and recomputation of interest u/s 234C were remitted to AO/JAO for verification and fresh computation.
Appeal by assessee was partly allowed. ITAT held that separate TP benchmarking for royalty was unwarranted when TNMM was accepted for other international transactions; assessee's TNMM-based ALP for royalty was upheld. Exemption u/s 10AA and deduction u/s 80JJAA, disallowed by CPC for a return filed a few hours late due to portal glitches, were sustained as valid, the due-date condition not being applicable for A.Y. 2018-19. Disallowance u/s 14A as made by AO was upheld, but ITAT directed that such disallowance not be added while computing book profits u/s 115JB. Deduction u/s 35(2AB), correction of double taxation of LTCG, and recomputation of interest u/s 234C were remitted to AO/JAO for verification and fresh computation.
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