https://www.taxtmi.com/caselaws?id=311750 ITAT Ahmedabad allowed the assessee's appeal in this sixteen-year-old transfer pricing dispute for A.Y. 2006-07. The tribunal deleted TP adjustments on sales to associated enterprises, finding revenue authorities failed to examine evidence despite clear directions. Prior period expenditure disallowance was deleted as tax-neutral with no revenue impact. Commission income addition was deleted as it represented reversal of earlier expenses. Quantity discount to AEs was allowed as per established commercial policy. Section 14A disallowance was restricted to Rs. 2,25,000 based on scientific calculation. Book profit enhancement under section 115JB was not required for section 14A disallowance. en-us Tue, 12 Jul 2022 00:00:00 +0530 Thu, 11 Jan 2024 09:26:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311750 ITAT Ahmedabad allowed the assessee's appeal in this sixteen-year-old transfer pricing dispute for A.Y. 2006-07. The tribunal deleted TP adjustments on sales to associated enterprises, finding revenue authorities failed to examine evidence despite clear directions. Prior period expenditure disallowance was deleted as tax-neutral with no revenue impact. Commission income addition was deleted as it represented reversal of earlier expenses. Quantity discount to AEs was allowed as per established commercial policy. Section 14A disallowance was restricted to Rs. 2,25,000 based on scientific calculation. Book profit enhancement under section 115JB was not required for section 14A disallowance. Case-Laws Income Tax Tue, 12 Jul 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311750