https://www.taxtmi.com/caselaws?id=449235 The ITAT Bangalore ruled on multiple issues. For TP adjustment regarding royalty payment benchmarking, the Tribunal held that separate benchmarking is unnecessary when TNMM approach is adopted at entity level, favoring the assessee based on precedent from assessment years 2015-16 and 2016-17. On DDT taxability, following the Special Bench decision in Total Oil India Pvt. Ltd., the Tribunal ruled against the assessee, holding that DDT under Section 115-O applies at statutory rates, not DTAA rates, unless the treaty specifically extends protection to domestic companies paying DDT. Interest under sections 234B and 234C was deemed consequential and mandatory. en-us Mon, 22 Jan 2024 00:00:00 +0530 Mon, 17 Mar 2025 10:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449235 The ITAT Bangalore ruled on multiple issues. For TP adjustment regarding royalty payment benchmarking, the Tribunal held that separate benchmarking is unnecessary when TNMM approach is adopted at entity level, favoring the assessee based on precedent from assessment years 2015-16 and 2016-17. On DDT taxability, following the Special Bench decision in Total Oil India Pvt. Ltd., the Tribunal ruled against the assessee, holding that DDT under Section 115-O applies at statutory rates, not DTAA rates, unless the treaty specifically extends protection to domestic companies paying DDT. Interest under sections 234B and 234C was deemed consequential and mandatory. Case-Laws Income Tax Mon, 22 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449235