https://www.taxtmi.com/caselaws?id=447543 ITAT Bangalore remanded transfer pricing adjustment issue to AO/TPO for fresh consideration, noting failure to analyze agreements, services rendered, and benchmarking methods between assessee and associated enterprises. Tribunal found TPO's 1/5th expense apportionment constituted double addition contrary to transfer pricing principles. Regarding depreciation, ITAT directed AO to allow 16% depreciation on CG/TX cards and switches instead of 60%, following coordinate bench precedent. For foreign tax credit, tribunal remanded matter to AO for verification of attributable amounts to Indian income, directing proper hearing opportunities for assessee. en-us Fri, 22 Dec 2023 00:00:00 +0530 Thu, 28 Dec 2023 14:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447543 ITAT Bangalore remanded transfer pricing adjustment issue to AO/TPO for fresh consideration, noting failure to analyze agreements, services rendered, and benchmarking methods between assessee and associated enterprises. Tribunal found TPO's 1/5th expense apportionment constituted double addition contrary to transfer pricing principles. Regarding depreciation, ITAT directed AO to allow 16% depreciation on CG/TX cards and switches instead of 60%, following coordinate bench precedent. For foreign tax credit, tribunal remanded matter to AO for verification of attributable amounts to Indian income, directing proper hearing opportunities for assessee. Case-Laws Income Tax Fri, 22 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447543