https://www.taxtmi.com/caselaws?id=236126 ITAT Del. partly allowed the appeal of the assessee. The tribunal held that commission expenses suo motu excluded in the revised return must be excluded from operating costs and accepted the assessee's corrected profit margin, deciding for the assessee on that point. It rejected three comparables for lack of current-year data and sustained reliance on a single comparable for ALP, deciding against the assessee on comparability, pre-operation expense exclusion, deviations from book profits, and capacity-utilisation adjustments. The 5% margin relief was allowed for the manufacturing segment but not for marketing support. Disallowance under section 40(a)(ia) was upheld, while depreciation on printers/UPS was allowed as computer assets. en-us Fri, 29 Apr 2011 00:00:00 +0530 Fri, 22 Aug 2025 12:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=236126 ITAT Del. partly allowed the appeal of the assessee. The tribunal held that commission expenses suo motu excluded in the revised return must be excluded from operating costs and accepted the assessee's corrected profit margin, deciding for the assessee on that point. It rejected three comparables for lack of current-year data and sustained reliance on a single comparable for ALP, deciding against the assessee on comparability, pre-operation expense exclusion, deviations from book profits, and capacity-utilisation adjustments. The 5% margin relief was allowed for the manufacturing segment but not for marketing support. Disallowance under section 40(a)(ia) was upheld, while depreciation on printers/UPS was allowed as computer assets. Case-Laws Income Tax Fri, 29 Apr 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=236126