https://www.taxtmi.com/caselaws?id=302066 ITAT Bangalore remitted multiple transfer-pricing issues to the AO/TPO for fresh determination: capacity-utilisation adjustments (direct the AO/TPO to obtain comparable companies' data under s.133(6) if not publicly available), elimination of customs duty, air-freight and foreign-exchange fluctuation adjustments to determine ALP. Amortisation of goodwill was held non-operating and decided for the assessee. TP adjustments were limited to international/AE transactions only. Two software product companies were excluded from comparables and specific other comparables were accepted subject to AO/TPO verification. Provision for warranty upheld on a scientific basis to be allowed proportionately using prior five years' data. Annual licence-fee treatment was remanded with directions to admit DRP-filed evidence. Appeal partly allowed. en-us Wed, 24 Nov 2021 00:00:00 +0530 Mon, 01 Sep 2025 14:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=302066 ITAT Bangalore remitted multiple transfer-pricing issues to the AO/TPO for fresh determination: capacity-utilisation adjustments (direct the AO/TPO to obtain comparable companies' data under s.133(6) if not publicly available), elimination of customs duty, air-freight and foreign-exchange fluctuation adjustments to determine ALP. Amortisation of goodwill was held non-operating and decided for the assessee. TP adjustments were limited to international/AE transactions only. Two software product companies were excluded from comparables and specific other comparables were accepted subject to AO/TPO verification. Provision for warranty upheld on a scientific basis to be allowed proportionately using prior five years' data. Annual licence-fee treatment was remanded with directions to admit DRP-filed evidence. Appeal partly allowed. Case-Laws Income Tax Wed, 24 Nov 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=302066