https://www.taxtmi.com/caselaws?id=302393 ITAT Pune held that subsidy of Rs. 89.73 crore received under the Maharashtra PSI scheme was a capital receipt, linked to setting up industrial units in less developed areas, and therefore not chargeable to tax for AY 2014-15. As a corollary, the subsidy was excluded from operating revenue for determining ALP under TNMM for the Manufacturing segment. The Tribunal further upheld the DRP's view that customs duty differences could not justify reducing comparables' margins absent evidence of different duty rates. In transfer pricing, Bharat Earth Movers Ltd. was excluded from the comparables following earlier precedent, while JCB India Ltd. was retained. The AO/TPO was directed to restrict TP adjustment only to international transactions in the Manufacturing segment. en-us Mon, 06 Dec 2021 00:00:00 +0530 Fri, 05 Dec 2025 13:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=302393 ITAT Pune held that subsidy of Rs. 89.73 crore received under the Maharashtra PSI scheme was a capital receipt, linked to setting up industrial units in less developed areas, and therefore not chargeable to tax for AY 2014-15. As a corollary, the subsidy was excluded from operating revenue for determining ALP under TNMM for the Manufacturing segment. The Tribunal further upheld the DRP's view that customs duty differences could not justify reducing comparables' margins absent evidence of different duty rates. In transfer pricing, Bharat Earth Movers Ltd. was excluded from the comparables following earlier precedent, while JCB India Ltd. was retained. The AO/TPO was directed to restrict TP adjustment only to international transactions in the Manufacturing segment. Case-Laws Income Tax Mon, 06 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=302393