https://www.taxtmi.com/caselaws?id=411330 The ITAT partly allowed the appeal, directing a re-examination and factual verification on several issues. The ITAT emphasized adherence to principles of natural justice and proper benchmarking methods for determining the ALP of international transactions. The matter was remanded to the DRP for fresh determination of the ALP regarding the adjustment on account of capital goods purchased from AE, emphasizing the lack of opportunity given to the assessee and the absence of evidence. The AO was instructed to re-examine the allowability and relevant year of liquidated damages and to verify the factual basis for disallowance of interest on a foreign term loan. The ITAT also directed the submission of a reconciliation statement to address a revenue discrepancy in Form 26AS and rectification of the oversight in considering the order under section 154 reducing the TP addition. en-us Mon, 16 Aug 2021 00:00:00 +0530 Mon, 23 Aug 2021 08:41:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=411330 The ITAT partly allowed the appeal, directing a re-examination and factual verification on several issues. The ITAT emphasized adherence to principles of natural justice and proper benchmarking methods for determining the ALP of international transactions. The matter was remanded to the DRP for fresh determination of the ALP regarding the adjustment on account of capital goods purchased from AE, emphasizing the lack of opportunity given to the assessee and the absence of evidence. The AO was instructed to re-examine the allowability and relevant year of liquidated damages and to verify the factual basis for disallowance of interest on a foreign term loan. The ITAT also directed the submission of a reconciliation statement to address a revenue discrepancy in Form 26AS and rectification of the oversight in considering the order under section 154 reducing the TP addition. Case-Laws Income Tax Mon, 16 Aug 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=411330