https://www.taxtmi.com/caselaws?id=759422 ITAT DELHI allowed assessee's appeal partly. TP adjustment for trademark fee payment deleted as assessee's operating margin (6.96%) exceeded comparables (2.77%), establishing arm's length pricing under TNMM. Addition for outstanding receivables deleted since payables to AEs were higher and no interest charged by AEs. Purchase/sale of finished goods remanded to TPO for fresh examination. Regional service charges and accounting support services remanded with directions to demonstrate actual expenses and mark-up. Advertisement expenditure disallowance deleted following previous favorable decisions. ESI contribution disallowance upheld following SC precedent in Checkmate Services requiring timely deposit. en-us Fri, 26 Jul 2024 00:00:00 +0530 Mon, 30 Sep 2024 08:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759422 ITAT DELHI allowed assessee's appeal partly. TP adjustment for trademark fee payment deleted as assessee's operating margin (6.96%) exceeded comparables (2.77%), establishing arm's length pricing under TNMM. Addition for outstanding receivables deleted since payables to AEs were higher and no interest charged by AEs. Purchase/sale of finished goods remanded to TPO for fresh examination. Regional service charges and accounting support services remanded with directions to demonstrate actual expenses and mark-up. Advertisement expenditure disallowance deleted following previous favorable decisions. ESI contribution disallowance upheld following SC precedent in Checkmate Services requiring timely deposit. Case-Laws Income Tax Fri, 26 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759422