https://www.taxtmi.com/caselaws?id=445294 The ITAT Chennai ruled in favor of the assessee on transfer pricing benchmarking, accepting entity-level comparison over unit-level comparison based on consistency principle and identical services across units. The tribunal excluded nine external comparables due to functional dissimilarity, product-based business models, or significant size differences. For Section 10A/10B exemption computation, freight and telecommunication expenses were ordered excluded from both export and total turnover following SC precedent. Civil and tiling expenses were treated as capital expenditure as the assessee had capitalized them. Licensed software expenses remained capital following earlier ITAT precedent. The Section 14A disallowance issue was remanded to AO for fresh consideration without applying Rule 8D. en-us Fri, 06 Oct 2023 00:00:00 +0530 Sat, 04 Nov 2023 23:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445294 The ITAT Chennai ruled in favor of the assessee on transfer pricing benchmarking, accepting entity-level comparison over unit-level comparison based on consistency principle and identical services across units. The tribunal excluded nine external comparables due to functional dissimilarity, product-based business models, or significant size differences. For Section 10A/10B exemption computation, freight and telecommunication expenses were ordered excluded from both export and total turnover following SC precedent. Civil and tiling expenses were treated as capital expenditure as the assessee had capitalized them. Licensed software expenses remained capital following earlier ITAT precedent. The Section 14A disallowance issue was remanded to AO for fresh consideration without applying Rule 8D. Case-Laws Income Tax Fri, 06 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445294