https://www.taxtmi.com/caselaws?id=205632 ITAT, Bangalore upheld a transfer-pricing adjustment using TNMM with a combined set of 12 comparables, finding a differential operating margin of 6.77% and sustaining an ALP adjustment against the assessee. A termination compensation of Rs. 1.05 crores was treated as an extraordinary item and excluded from operating expenses for margin computation, leading to disallowance upheld. Conversely, the tribunal ruled in favour of the assessee on lease-line/high-speed link charges, holding that export turnover adjustments must be reflected in total turnover so such expenses attributable to exports cannot be included. en-us Mon, 30 Aug 2010 00:00:00 +0530 Wed, 27 Aug 2025 13:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=205632 ITAT, Bangalore upheld a transfer-pricing adjustment using TNMM with a combined set of 12 comparables, finding a differential operating margin of 6.77% and sustaining an ALP adjustment against the assessee. A termination compensation of Rs. 1.05 crores was treated as an extraordinary item and excluded from operating expenses for margin computation, leading to disallowance upheld. Conversely, the tribunal ruled in favour of the assessee on lease-line/high-speed link charges, holding that export turnover adjustments must be reflected in total turnover so such expenses attributable to exports cannot be included. Case-Laws Income Tax Mon, 30 Aug 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=205632