https://www.taxtmi.com/caselaws?id=312257 The ITAT Bangalore remanded several transfer pricing comparables back to AO/TPO for verification of functional similarity under TNMM method. The tribunal excluded certain comparables like Dembla Valves Ltd for manufacturing different products and directed verification of RPT filters for three companies at 15% threshold. Remi Sales Engineering Ltd was included as comparable since revenue accepted it in preceding year without cogent reasons for exclusion. Working capital adjustment was allowed following coordinate bench precedent, noting revenue has powers under section 133(6) to obtain comparable company details. Global sales and marketing expenses were treated as operating costs to be allocated based on turnover ratio. TDS issue on expat salary reimbursement was remanded for verification. DDT refund claim was allowed following Special Bench decision in Total Oil India case. en-us Wed, 17 May 2023 00:00:00 +0530 Thu, 08 Feb 2024 18:14:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312257 The ITAT Bangalore remanded several transfer pricing comparables back to AO/TPO for verification of functional similarity under TNMM method. The tribunal excluded certain comparables like Dembla Valves Ltd for manufacturing different products and directed verification of RPT filters for three companies at 15% threshold. Remi Sales Engineering Ltd was included as comparable since revenue accepted it in preceding year without cogent reasons for exclusion. Working capital adjustment was allowed following coordinate bench precedent, noting revenue has powers under section 133(6) to obtain comparable company details. Global sales and marketing expenses were treated as operating costs to be allocated based on turnover ratio. TDS issue on expat salary reimbursement was remanded for verification. DDT refund claim was allowed following Special Bench decision in Total Oil India case. Case-Laws Income Tax Wed, 17 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312257