https://www.taxtmi.com/caselaws?id=445338 ITAT Chennai dismissed revenue's appeal regarding transfer pricing adjustments and expense disallowances. The tribunal upheld CIT(A)'s exclusion of certain comparables including Power Systems Operations Corp. Ltd. (government entity with different functions), Apitco Ltd. (specialized consultancy), and Global Procurement Consultants Ltd. (high-end technical consultancy), finding them functionally incomparable to assessee's marketing support services. ITAT accepted inclusion of EDCIL Ltd. and In House Production Ltd. as comparables based on prior year acceptance without demonstrated functional changes. The tribunal also upheld CIT(A)'s decisions allowing advertisement/marketing expenses under section 37(1) and rejecting separate disallowance of management fees to associated enterprises after arm's length price determination. en-us Thu, 05 Oct 2023 00:00:00 +0530 Mon, 06 Nov 2023 10:36:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445338 ITAT Chennai dismissed revenue's appeal regarding transfer pricing adjustments and expense disallowances. The tribunal upheld CIT(A)'s exclusion of certain comparables including Power Systems Operations Corp. Ltd. (government entity with different functions), Apitco Ltd. (specialized consultancy), and Global Procurement Consultants Ltd. (high-end technical consultancy), finding them functionally incomparable to assessee's marketing support services. ITAT accepted inclusion of EDCIL Ltd. and In House Production Ltd. as comparables based on prior year acceptance without demonstrated functional changes. The tribunal also upheld CIT(A)'s decisions allowing advertisement/marketing expenses under section 37(1) and rejecting separate disallowance of management fees to associated enterprises after arm's length price determination. Case-Laws Income Tax Thu, 05 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445338