https://www.taxtmi.com/caselaws?id=456286 The ITAT Bangalore ruled on multiple transfer pricing and tax issues. For royalty adjustment, the Tribunal directed AO/TPO to consider royalty payment as operating cost and compare margins with comparable company. The distribution segment comparable selection was remitted back following earlier Tribunal decisions requiring consistency in proceedings. For software development segment, the Tribunal noted specific exclusion criteria for comparables. The Tribunal allowed deduction for lease payments as revenue expenditure, following Karnataka HC precedent. Written-off receivables issue was remitted for consequential order per DRP directions. TDS credit denial was sent back for verification. Interest under section 234A was held bad in law if return filed within due date. en-us Fri, 03 Feb 2023 00:00:00 +0530 Sat, 13 Jul 2024 08:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456286 The ITAT Bangalore ruled on multiple transfer pricing and tax issues. For royalty adjustment, the Tribunal directed AO/TPO to consider royalty payment as operating cost and compare margins with comparable company. The distribution segment comparable selection was remitted back following earlier Tribunal decisions requiring consistency in proceedings. For software development segment, the Tribunal noted specific exclusion criteria for comparables. The Tribunal allowed deduction for lease payments as revenue expenditure, following Karnataka HC precedent. Written-off receivables issue was remitted for consequential order per DRP directions. TDS credit denial was sent back for verification. Interest under section 234A was held bad in law if return filed within due date. Case-Laws Income Tax Fri, 03 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456286