https://www.taxtmi.com/caselaws?id=362628 The Tribunal partially allowed the appeal, ruling in favor of the assessee on various issues. It directed the Transfer Pricing Officer to reconsider the arm's length price in line with earlier decisions, leading to the deletion of additions. Additionally, it held that expenditure on royalty and technical fees was allowable as revenue deductions, deleting the corresponding addition. The disallowance of expenditure under Section 14A was deemed unsustainable due to the absence of a direct nexus, resulting in its deletion. Furthermore, the disallowance of set off of short-term capital losses under Section 94(8) was also deleted as the conditions for its application were not met. en-us Wed, 27 Jun 2018 00:00:00 +0530 Fri, 29 Jun 2018 07:17:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=362628 The Tribunal partially allowed the appeal, ruling in favor of the assessee on various issues. It directed the Transfer Pricing Officer to reconsider the arm's length price in line with earlier decisions, leading to the deletion of additions. Additionally, it held that expenditure on royalty and technical fees was allowable as revenue deductions, deleting the corresponding addition. The disallowance of expenditure under Section 14A was deemed unsustainable due to the absence of a direct nexus, resulting in its deletion. Furthermore, the disallowance of set off of short-term capital losses under Section 94(8) was also deleted as the conditions for its application were not met. Case-Laws Income Tax Wed, 27 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=362628