https://www.taxtmi.com/caselaws?id=456290 The ITAT Bangalore remanded the TP adjustment issue regarding royalty payments to the AO/TPO for comparison of margins with comparable company M/s. Advance Micronic Devices Ltd. The Tribunal deleted TP adjustment in trading segment as assessee's margin exceeded the median margin of 10.87% from 8 comparables selected by TPO. For comparable selection, companies with different turnover categories and functional dissimilarities were to be excluded. Regarding lease payment deduction, the Tribunal allowed the claim as revenue expenditure, finding no colourable device by assessee who remained only a lessee under the agreement. TDS credit issue was remitted for verification. en-us Wed, 15 Mar 2023 00:00:00 +0530 Sat, 13 Jul 2024 21:06:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456290 The ITAT Bangalore remanded the TP adjustment issue regarding royalty payments to the AO/TPO for comparison of margins with comparable company M/s. Advance Micronic Devices Ltd. The Tribunal deleted TP adjustment in trading segment as assessee's margin exceeded the median margin of 10.87% from 8 comparables selected by TPO. For comparable selection, companies with different turnover categories and functional dissimilarities were to be excluded. Regarding lease payment deduction, the Tribunal allowed the claim as revenue expenditure, finding no colourable device by assessee who remained only a lessee under the agreement. TDS credit issue was remitted for verification. Case-Laws Income Tax Wed, 15 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456290