https://www.taxtmi.com/caselaws?id=312248 ITAT Bangalore ruled on multiple transfer pricing and tax issues. The tribunal restored several claims to AO/TPO for fresh examination including treatment of construction contract provisions as non-operating, leverage consideration, and margin computation errors. For trading segment, tribunal directed adoption of operating profit/operating revenue as profit level indicator. Management and marketing fees were ordered to be treated as operating costs allocated proportionally. Section 14A disallowance was restricted to 10% of exempt dividend income since Rule 8D couldn't apply with nil opening/closing investment values. TDS credit, education cess deduction, and dividend distribution tax rate issues were restored to AO for examination following relevant judicial precedents. en-us Thu, 25 Nov 2021 00:00:00 +0530 Thu, 08 Feb 2024 18:14:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312248 ITAT Bangalore ruled on multiple transfer pricing and tax issues. The tribunal restored several claims to AO/TPO for fresh examination including treatment of construction contract provisions as non-operating, leverage consideration, and margin computation errors. For trading segment, tribunal directed adoption of operating profit/operating revenue as profit level indicator. Management and marketing fees were ordered to be treated as operating costs allocated proportionally. Section 14A disallowance was restricted to 10% of exempt dividend income since Rule 8D couldn't apply with nil opening/closing investment values. TDS credit, education cess deduction, and dividend distribution tax rate issues were restored to AO for examination following relevant judicial precedents. Case-Laws Income Tax Thu, 25 Nov 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312248