https://www.taxtmi.com/caselaws?id=446714 ITAT Mumbai held that director's remuneration including salary and commission must be benchmarked as a single aggregated transaction rather than separately. The aggregate remuneration-to-profit ratio of 4.36% fell within the acceptable range of comparables, making the TPO's transfer pricing adjustment unjustified. Additionally, Industrial Promotion Subsidies received from state governments for setting up new units were held to be capital in nature, not revenue, following established precedents. The tribunal directed deletion of transfer pricing adjustments and allowed the assessee's appeal on both grounds. en-us Tue, 03 Oct 2023 00:00:00 +0530 Fri, 08 Dec 2023 12:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446714 ITAT Mumbai held that director's remuneration including salary and commission must be benchmarked as a single aggregated transaction rather than separately. The aggregate remuneration-to-profit ratio of 4.36% fell within the acceptable range of comparables, making the TPO's transfer pricing adjustment unjustified. Additionally, Industrial Promotion Subsidies received from state governments for setting up new units were held to be capital in nature, not revenue, following established precedents. The tribunal directed deletion of transfer pricing adjustments and allowed the assessee's appeal on both grounds. Case-Laws Income Tax Tue, 03 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446714