https://www.taxtmi.com/caselaws?id=361076 ITAT upheld that the TPO's rejection of the assessee's TNMM was unsound as applicability was not discussed and prior ITAT orders favored the assessee; CIT(A)'s reliance on predecessor orders was sustained. Miscellaneous expenses addition reduced from Rs.15,00,000 to Rs.10,00,000. Amounts between related entities held adjustments, not loans, so s.2(22)(e) not attracted. Disallowance under s.40(a)(ia) deleted as TDS was deposited before return filing. Only current-year gratuity provision may be disallowed; opening balance to remain. AO to compute correct depreciation and include other income for s.10B eligibility; prior-period expenses may be set off against prior-period income. s.14A disallowance partly sustained at Rs.3,00,000. en-us Wed, 23 May 2018 00:00:00 +0530 Sat, 25 Oct 2025 13:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=361076 ITAT upheld that the TPO's rejection of the assessee's TNMM was unsound as applicability was not discussed and prior ITAT orders favored the assessee; CIT(A)'s reliance on predecessor orders was sustained. Miscellaneous expenses addition reduced from Rs.15,00,000 to Rs.10,00,000. Amounts between related entities held adjustments, not loans, so s.2(22)(e) not attracted. Disallowance under s.40(a)(ia) deleted as TDS was deposited before return filing. Only current-year gratuity provision may be disallowed; opening balance to remain. AO to compute correct depreciation and include other income for s.10B eligibility; prior-period expenses may be set off against prior-period income. s.14A disallowance partly sustained at Rs.3,00,000. Case-Laws Income Tax Wed, 23 May 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=361076