https://www.taxtmi.com/caselaws?id=456704 The ITAT Pune ruled on two key issues in this tax appeal. Regarding royalty expenditure classification, the tribunal held in favor of the assessee, determining such expenditure is revenue in nature rather than capital expenditure. The Department Representative conceded this position has been consistently upheld in prior cases. On the transfer pricing matter concerning DEMPE functions, the tribunal found the Transfer Pricing Officer failed to apply prescribed methods or provide comparable transactions to determine arm's length pricing. The tribunal remanded the transfer pricing issue back to the Assessing Officer for re-adjudication following natural justice principles. The appeal was allowed for statistical purposes. en-us Tue, 28 Feb 2023 00:00:00 +0530 Fri, 09 Aug 2024 08:57:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456704 The ITAT Pune ruled on two key issues in this tax appeal. Regarding royalty expenditure classification, the tribunal held in favor of the assessee, determining such expenditure is revenue in nature rather than capital expenditure. The Department Representative conceded this position has been consistently upheld in prior cases. On the transfer pricing matter concerning DEMPE functions, the tribunal found the Transfer Pricing Officer failed to apply prescribed methods or provide comparable transactions to determine arm's length pricing. The tribunal remanded the transfer pricing issue back to the Assessing Officer for re-adjudication following natural justice principles. The appeal was allowed for statistical purposes. Case-Laws Income Tax Tue, 28 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456704