Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
In transfer pricing, broad functional comparability under TNMM was applied: Bright Brothers Ltd. was retained because product differences did not matter where functions were broadly similar, and REIL Electricals India Ltd. was included as functionally similar. Working capital adjustment was treated as a valid claim and was directed to be allowed, subject to the assessee furnishing supporting details and data. On royalty, technical know-how and technical services, the Tribunal upheld deletion of the adjustment because CUP was adopted without comparable uncontrolled data and the principle of consistency supported the assessee, as no adjustment had been made in earlier or subsequent years on the same agreements.
In transfer pricing, broad functional comparability under TNMM was applied: Bright Brothers Ltd. was retained because product differences did not matter where functions were broadly similar, and REIL Electricals India Ltd. was included as functionally similar. Working capital adjustment was treated as a valid claim and was directed to be allowed, subject to the assessee furnishing supporting details and data. On royalty, technical know-how and technical services, the Tribunal upheld deletion of the adjustment because CUP was adopted without comparable uncontrolled data and the principle of consistency supported the assessee, as no adjustment had been made in earlier or subsequent years on the same agreements.
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