https://www.taxtmi.com/caselaws?id=752387 The ITAT Mumbai allowed the assessee's appeal regarding TP adjustments on exports to AEs in South Africa and Mexico, finding the assessee's transfer pricing study acceptable despite different accounting periods and database limitations. The tribunal noted AEs were in initial operational years with lower profitability than established comparables, indicating no under-invoicing. For section 35(2AB) deduction, the tribunal upheld CIT(A)'s decision favoring the assessee, noting DSIR approval requirements applied from 2016 onwards. The tribunal allowed section 32AC deduction as aggregate asset costs exceeded Rs. 100 crores threshold. Corporate guarantee commission TP adjustment deletion was upheld following Bombay HC precedent. Sales promotion expenses disallowance was remanded for fresh examination due to incorrect approaches by both authorities. en-us Thu, 01 Feb 2024 00:00:00 +0530 Wed, 08 May 2024 14:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752387 The ITAT Mumbai allowed the assessee's appeal regarding TP adjustments on exports to AEs in South Africa and Mexico, finding the assessee's transfer pricing study acceptable despite different accounting periods and database limitations. The tribunal noted AEs were in initial operational years with lower profitability than established comparables, indicating no under-invoicing. For section 35(2AB) deduction, the tribunal upheld CIT(A)'s decision favoring the assessee, noting DSIR approval requirements applied from 2016 onwards. The tribunal allowed section 32AC deduction as aggregate asset costs exceeded Rs. 100 crores threshold. Corporate guarantee commission TP adjustment deletion was upheld following Bombay HC precedent. Sales promotion expenses disallowance was remanded for fresh examination due to incorrect approaches by both authorities. Case-Laws Income Tax Thu, 01 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752387