https://www.taxtmi.com/caselaws?id=304526 ITAT PUNE (AT) allowed multiple grounds for the assessee: upheld aggregation for benchmarking manufacturing transactions; directed inclusion of export incentives in operating income; confirmed PLI should be measured as net profit to sales; directed AO/TPO to apply a 5% tolerance under proviso to s.92C(2) where variation falls within range; remanded the management-fee issue to AO/TPO to examine applicability of an APA and relevant agreements; remitted s.14A disallowance for fresh adjudication per prior Tribunal order; held DSIR certification governs entitlement under s.35(2AB) and cannot be interfered with by the Tribunal; allowed claim for additional depreciation per binding HC precedent. en-us Wed, 19 Feb 2020 00:00:00 +0530 Wed, 27 Aug 2025 14:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=304526 ITAT PUNE (AT) allowed multiple grounds for the assessee: upheld aggregation for benchmarking manufacturing transactions; directed inclusion of export incentives in operating income; confirmed PLI should be measured as net profit to sales; directed AO/TPO to apply a 5% tolerance under proviso to s.92C(2) where variation falls within range; remanded the management-fee issue to AO/TPO to examine applicability of an APA and relevant agreements; remitted s.14A disallowance for fresh adjudication per prior Tribunal order; held DSIR certification governs entitlement under s.35(2AB) and cannot be interfered with by the Tribunal; allowed claim for additional depreciation per binding HC precedent. Case-Laws Income Tax Wed, 19 Feb 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=304526