https://www.taxtmi.com/caselaws?id=238100 ITAT Mumbai allowed employer's contributions to PF, ESIC, and superannuation funds paid after the grace period but before filing the return as deductible under section 43B, following SC precedent. Depreciation on plant and machinery used for non-manufacturing activities was restored, favoring the assessee. On transfer pricing, the Tribunal held that the most appropriate method for determining ALP depends on facts; even if TNMM was initially chosen, other methods like RPM could be considered if more reliable. Professional fees disallowance was deleted as liability crystallizes on bill receipt, and no excess payment was established. Regarding unsold toys purchased from the AE, the Tribunal accepted internal comparables (export sales to third parties) to determine ALP, directing reassessment considering segmental details. Overall, the ITAT ruled in favor of the assessee on all disputed issues. en-us Wed, 12 Jun 2013 00:00:00 +0530 Wed, 01 Jul 2026 15:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=238100 ITAT Mumbai allowed employer's contributions to PF, ESIC, and superannuation funds paid after the grace period but before filing the return as deductible under section 43B, following SC precedent. Depreciation on plant and machinery used for non-manufacturing activities was restored, favoring the assessee. On transfer pricing, the Tribunal held that the most appropriate method for determining ALP depends on facts; even if TNMM was initially chosen, other methods like RPM could be considered if more reliable. Professional fees disallowance was deleted as liability crystallizes on bill receipt, and no excess payment was established. Regarding unsold toys purchased from the AE, the Tribunal accepted internal comparables (export sales to third parties) to determine ALP, directing reassessment considering segmental details. Overall, the ITAT ruled in favor of the assessee on all disputed issues. Case-Laws Income Tax Wed, 12 Jun 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=238100