https://www.taxtmi.com/caselaws?id=762449 ITAT Chennai dismissed assessee's appeal regarding segmentation of UDS and CM activities, upholding TPO's treatment as composite segments due to absence of separate manufacturing facilities and insufficient evidence. However, TPO was directed to re-examine rejection of overseas associated enterprises as tested parties after proper verification. Brand development fee additions were deleted following precedent decisions. Two companies were excluded from comparable analysis - Infosys BPO Ltd due to size disparity and HSCC India Ltd being government entity in different business. Extended warranty advance receipts were held not taxable in sale year to avoid double taxation. Provision expense disallowance and unabsorbed depreciation matters were remanded for fresh adjudication with proper verification. en-us Fri, 22 Nov 2024 00:00:00 +0530 Sat, 30 Nov 2024 14:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762449 ITAT Chennai dismissed assessee's appeal regarding segmentation of UDS and CM activities, upholding TPO's treatment as composite segments due to absence of separate manufacturing facilities and insufficient evidence. However, TPO was directed to re-examine rejection of overseas associated enterprises as tested parties after proper verification. Brand development fee additions were deleted following precedent decisions. Two companies were excluded from comparable analysis - Infosys BPO Ltd due to size disparity and HSCC India Ltd being government entity in different business. Extended warranty advance receipts were held not taxable in sale year to avoid double taxation. Provision expense disallowance and unabsorbed depreciation matters were remanded for fresh adjudication with proper verification. Case-Laws Income Tax Fri, 22 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762449