https://www.taxtmi.com/caselaws?id=282617 ITAT DELHI - AT allowed most grounds in favour of the assessee. TP adjustments for AMP and royalty were disallowed following HC precedent that BLT cannot alone establish an international transaction and that royalty/technical fees were revenue in nature; double disallowance of royalty was reversed. Deductions for after-sales service provisions and warranty provisions were upheld as consistent with accounting standards and prior Tribunal treatment. Disallowance under s.37(1) was not sustained. Short credit of advance tax was remanded to the AO for verification with opportunity of hearing; that ground was partly allowed for statistical purposes. en-us Tue, 17 Apr 2018 00:00:00 +0530 Wed, 08 Oct 2025 16:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=282617 ITAT DELHI - AT allowed most grounds in favour of the assessee. TP adjustments for AMP and royalty were disallowed following HC precedent that BLT cannot alone establish an international transaction and that royalty/technical fees were revenue in nature; double disallowance of royalty was reversed. Deductions for after-sales service provisions and warranty provisions were upheld as consistent with accounting standards and prior Tribunal treatment. Disallowance under s.37(1) was not sustained. Short credit of advance tax was remanded to the AO for verification with opportunity of hearing; that ground was partly allowed for statistical purposes. Case-Laws Income Tax Tue, 17 Apr 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=282617