https://www.taxtmi.com/caselaws?id=459198 The ITAT Delhi allowed the assessee's appeal for statistical purposes on multiple grounds. Regarding TP adjustment for corporate charges under cost allocation agreement with associated enterprise, the Tribunal admitted additional evidence and remanded the matter to TPO for fresh adjudication, noting that DRP failed to properly consider CUP method for benchmarking. On project expenses classification, the Tribunal ruled in favor of treating them as revenue expenditure, citing consistent precedent from earlier assessment years where similar treatment was upheld through HC and SC. For section 10B deduction disallowance, the Tribunal restored the matter to AO with directions to allow section 10A exemption if requisites are satisfied, alternatively allowing section 80HHE deduction. en-us Thu, 07 Jan 2016 00:00:00 +0530 Wed, 04 Dec 2024 21:50:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459198 The ITAT Delhi allowed the assessee's appeal for statistical purposes on multiple grounds. Regarding TP adjustment for corporate charges under cost allocation agreement with associated enterprise, the Tribunal admitted additional evidence and remanded the matter to TPO for fresh adjudication, noting that DRP failed to properly consider CUP method for benchmarking. On project expenses classification, the Tribunal ruled in favor of treating them as revenue expenditure, citing consistent precedent from earlier assessment years where similar treatment was upheld through HC and SC. For section 10B deduction disallowance, the Tribunal restored the matter to AO with directions to allow section 10A exemption if requisites are satisfied, alternatively allowing section 80HHE deduction. Case-Laws Income Tax Thu, 07 Jan 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459198