https://www.taxtmi.com/caselaws?id=311488 The ITAT Bangalore remitted the duty drawback issue to the TPO for verification, holding that duty drawback constitutes operating profit as it compensates for duties already included in raw material costs. The tribunal excluded UMW Industries Ltd from comparables, finding its guidance wire manufacturing for defense activities functionally different from the assessee's textile machinery supply. Lohia Corporation Ltd was also excluded due to significant R&D expenditure exceeding 3% threshold. The tribunal restricted TP adjustments to only international transactions with associated enterprises and directed working capital adjustments based on actual figures after comparable company exclusions. en-us Tue, 14 Feb 2023 00:00:00 +0530 Thu, 28 Dec 2023 20:51:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311488 The ITAT Bangalore remitted the duty drawback issue to the TPO for verification, holding that duty drawback constitutes operating profit as it compensates for duties already included in raw material costs. The tribunal excluded UMW Industries Ltd from comparables, finding its guidance wire manufacturing for defense activities functionally different from the assessee's textile machinery supply. Lohia Corporation Ltd was also excluded due to significant R&D expenditure exceeding 3% threshold. The tribunal restricted TP adjustments to only international transactions with associated enterprises and directed working capital adjustments based on actual figures after comparable company exclusions. Case-Laws Income Tax Tue, 14 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311488