https://www.taxtmi.com/caselaws?id=407658 The ITAT Hyderabad ruled in favor of the assessee on multiple issues. Regarding transfer pricing, the tribunal held that MAP margins of 15.49%, 15.34%, and 15.76% established for USA-based international transactions should apply to remaining non-USA transactions with associated enterprises, as the TPO made no distinction in ALP determination. For expenditure on leasehold premises improvements, the tribunal allowed the claim as revenue expenditure, rejecting the revenue's disallowance under section 37. The penalty under section 271(1)(c) was deleted after finding that incorrect figures in Form 3CEB resulted from TPO's admitted mistake rather than concealment by the assessee. en-us Wed, 24 Mar 2021 00:00:00 +0530 Wed, 05 Mar 2025 17:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=407658 The ITAT Hyderabad ruled in favor of the assessee on multiple issues. Regarding transfer pricing, the tribunal held that MAP margins of 15.49%, 15.34%, and 15.76% established for USA-based international transactions should apply to remaining non-USA transactions with associated enterprises, as the TPO made no distinction in ALP determination. For expenditure on leasehold premises improvements, the tribunal allowed the claim as revenue expenditure, rejecting the revenue's disallowance under section 37. The penalty under section 271(1)(c) was deleted after finding that incorrect figures in Form 3CEB resulted from TPO's admitted mistake rather than concealment by the assessee. Case-Laws Income Tax Wed, 24 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=407658