https://www.taxtmi.com/caselaws?id=275299 ITAT Delhi partly allowed the assessee's appeal and dismissed the Revenue's cross-objection. The Tribunal excluded Brescon Corporate Advisors Limited from the comparables for determining the arm's length price, rejecting the Revenue's contention and confirming no estoppel against the assessee for changing comparables. The issue regarding inclusion of non-operating incomes in computing profits was remanded to the TPO for re-examination. The addition relating to salary and bonus payments to directors was deleted following the HC decision in the assessee's favor. Severance payment to a non-shareholder director was held to be an allowable business expenditure, not a capital expense. Overall, the appeal was partly allowed on multiple grounds concerning transfer pricing and expenditure disallowances. en-us Thu, 09 Feb 2017 00:00:00 +0530 Wed, 23 Jul 2025 11:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=275299 ITAT Delhi partly allowed the assessee's appeal and dismissed the Revenue's cross-objection. The Tribunal excluded Brescon Corporate Advisors Limited from the comparables for determining the arm's length price, rejecting the Revenue's contention and confirming no estoppel against the assessee for changing comparables. The issue regarding inclusion of non-operating incomes in computing profits was remanded to the TPO for re-examination. The addition relating to salary and bonus payments to directors was deleted following the HC decision in the assessee's favor. Severance payment to a non-shareholder director was held to be an allowable business expenditure, not a capital expense. Overall, the appeal was partly allowed on multiple grounds concerning transfer pricing and expenditure disallowances. Case-Laws Income Tax Thu, 09 Feb 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=275299