https://www.taxtmi.com/caselaws?id=445697 ITAT DELHI upheld CIT(A)'s order regarding transfer pricing adjustments. The TPO's action to charge mark-up on third party costs was partially rejected. Advertisement, publicity, and trade event expenses were treated as pass-through costs without mark-up since they were undertaken at overseas entity's request with budget controlled by associated enterprise and risks borne by them. However, other expenses remained part of cost base requiring mark-up. Regarding foreign exchange losses, ITAT held these should be excluded from profit level indicator computation as they are operational/financial charges in nature, consistent with treatment of comparable companies in benchmarking analysis. en-us Fri, 10 Nov 2023 00:00:00 +0530 Thu, 16 Nov 2023 12:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445697 ITAT DELHI upheld CIT(A)'s order regarding transfer pricing adjustments. The TPO's action to charge mark-up on third party costs was partially rejected. Advertisement, publicity, and trade event expenses were treated as pass-through costs without mark-up since they were undertaken at overseas entity's request with budget controlled by associated enterprise and risks borne by them. However, other expenses remained part of cost base requiring mark-up. Regarding foreign exchange losses, ITAT held these should be excluded from profit level indicator computation as they are operational/financial charges in nature, consistent with treatment of comparable companies in benchmarking analysis. Case-Laws Income Tax Fri, 10 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445697