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...
Under Rule 10B, reasonably accurate adjustments may be made in TNMM where a difference materially distorts net profit margin; depreciation on in-house software was treated as requiring adjustment because it substantially affected the assessee's PLI and the benchmarking exercise, and recomputation was directed. The Tribunal also accepted an upper turnover filter for comparability, holding that companies with vastly higher turnover than the assessee were not meaningfully comparable and must be excluded. On functional dissimilarity, the Tribunal found the existing record insufficient for a final finding because relevant submissions had not been properly examined, and remitted the issue to the TPO for fresh consideration.
Under Rule 10B, reasonably accurate adjustments may be made in TNMM where a difference materially distorts net profit margin; depreciation on in-house software was treated as requiring adjustment because it substantially affected the assessee's PLI and the benchmarking exercise, and recomputation was directed. The Tribunal also accepted an upper turnover filter for comparability, holding that companies with vastly higher turnover than the assessee were not meaningfully comparable and must be excluded. On functional dissimilarity, the Tribunal found the existing record insufficient for a final finding because relevant submissions had not been properly examined, and remitted the issue to the TPO for fresh consideration.
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