https://www.taxtmi.com/caselaws?id=306981 The appeals were filed against transfer pricing adjustments on management fees paid to an associated enterprise, adhoc addition of management fees, and disallowance of excess depreciation on electrical fittings. The Appellate Tribunal ITAT Delhi allowed the appeals of the assessee, directing the Revenue to allow depreciation at 15% instead of 10% for electrical fittings. It held that Sections 40(a)(ia) and 92CA(3) of the Act operate simultaneously, rejecting the double taxation argument raised by the appellant regarding the transfer pricing adjustments. The misapplication of Section 92CA(3) in adding management fees was also criticized, emphasizing the need for proper application of prescribed methods. en-us Tue, 31 May 2022 00:00:00 +0530 Fri, 10 Mar 2023 20:56:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306981 The appeals were filed against transfer pricing adjustments on management fees paid to an associated enterprise, adhoc addition of management fees, and disallowance of excess depreciation on electrical fittings. The Appellate Tribunal ITAT Delhi allowed the appeals of the assessee, directing the Revenue to allow depreciation at 15% instead of 10% for electrical fittings. It held that Sections 40(a)(ia) and 92CA(3) of the Act operate simultaneously, rejecting the double taxation argument raised by the appellant regarding the transfer pricing adjustments. The misapplication of Section 92CA(3) in adding management fees was also criticized, emphasizing the need for proper application of prescribed methods. Case-Laws Income Tax Tue, 31 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306981