https://www.taxtmi.com/caselaws?id=396099 ITAT KOLKATA - AT allowed most of the assessee's claims. Royalty payments to AEs were upheld as previously accepted, and disallowance for two brands was deleted. AMP expenses were held not to be international transactions. The comparable-party mark-up issue was remitted to the TPO for fresh adjudication with documents on record, and the TPO was directed to implement rectified DRP directions on export adjustments. Allocation of residual overheads by employee-and-sales metrics was upheld. Profits from scrap sales qualify for deduction under section 80IC. Quantification of excess interest disallowance and refund of DDT to non-resident shareholders were remitted for factual verification. Education cess on income tax was allowed as expenditure. en-us Wed, 17 Jun 2020 00:00:00 +0530 Fri, 31 Oct 2025 12:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=396099 ITAT KOLKATA - AT allowed most of the assessee's claims. Royalty payments to AEs were upheld as previously accepted, and disallowance for two brands was deleted. AMP expenses were held not to be international transactions. The comparable-party mark-up issue was remitted to the TPO for fresh adjudication with documents on record, and the TPO was directed to implement rectified DRP directions on export adjustments. Allocation of residual overheads by employee-and-sales metrics was upheld. Profits from scrap sales qualify for deduction under section 80IC. Quantification of excess interest disallowance and refund of DDT to non-resident shareholders were remitted for factual verification. Education cess on income tax was allowed as expenditure. Case-Laws Income Tax Wed, 17 Jun 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=396099