https://www.taxtmi.com/caselaws?id=311022 The ITAT PUNE upheld the CIT(A)'s restriction of service charges and reimbursements to 30% disallowance, following coordinate bench precedent. Travelling expenses disallowance was limited to 10% on estimation basis. The tribunal accepted the assessee's position on depreciation of coolers provided to bottlers/vendors. TP adjustment matters were remanded to DRP for fresh adjudication within three hearings due to procedural deficiencies. Marketing support services disallowance was restricted to 5% only, considering verification difficulties after significant time lapse. AMP expenses were held not to constitute international transactions under Section 92B, following Maruti Suzuki precedent, reversing lower authorities' decision on this issue. en-us Thu, 12 Jan 2023 00:00:00 +0530 Sun, 03 Dec 2023 18:52:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311022 The ITAT PUNE upheld the CIT(A)'s restriction of service charges and reimbursements to 30% disallowance, following coordinate bench precedent. Travelling expenses disallowance was limited to 10% on estimation basis. The tribunal accepted the assessee's position on depreciation of coolers provided to bottlers/vendors. TP adjustment matters were remanded to DRP for fresh adjudication within three hearings due to procedural deficiencies. Marketing support services disallowance was restricted to 5% only, considering verification difficulties after significant time lapse. AMP expenses were held not to constitute international transactions under Section 92B, following Maruti Suzuki precedent, reversing lower authorities' decision on this issue. Case-Laws Income Tax Thu, 12 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311022