https://www.taxtmi.com/caselaws?id=449334 ITAT Bangalore held that TP adjustments should be restricted only to AE transactions, not all transactions, following Bombay HC precedent upheld by SC. On comparability, TCIL's trading segment profitability to be considered separately, with remand for fresh consideration regarding persistent loss-making status. Zicom Electronics and Adtech Systems deemed functionally comparable as trading companies. Commission income excluded from trading segment due to unclear service nature. GSMAF/MF expenses treated as operating costs allocated per turnover ratio. Section 14A disallowance restricted to 10% of exempt dividend income. DDT and education cess issues left open and dismissed respectively. en-us Thu, 01 Feb 2024 00:00:00 +0530 Fri, 23 May 2025 16:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449334 ITAT Bangalore held that TP adjustments should be restricted only to AE transactions, not all transactions, following Bombay HC precedent upheld by SC. On comparability, TCIL's trading segment profitability to be considered separately, with remand for fresh consideration regarding persistent loss-making status. Zicom Electronics and Adtech Systems deemed functionally comparable as trading companies. Commission income excluded from trading segment due to unclear service nature. GSMAF/MF expenses treated as operating costs allocated per turnover ratio. Section 14A disallowance restricted to 10% of exempt dividend income. DDT and education cess issues left open and dismissed respectively. Case-Laws Income Tax Thu, 01 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449334