https://www.taxtmi.com/caselaws?id=762903 The ITAT Mumbai directed the TPO to select fresh comparables dealing specifically in electronic products rather than electrical products, following a chartered engineer's certificate establishing that switch mode power supply (SMPS) is electronic, not electrical. The tribunal emphasized that electronic and electrical products cannot be compared, requiring technical expert certification for proper comparable selection. For the 100% EOU assessee, filters of export turnover exceeding 75% and related party transactions below 25% must be applied. The TPO was also directed to consider capacity utilization in ALP determination. Cash payment additions under section 40A(a) exceeding Rs. 20,000 require further verification with adequate opportunity for the assessee. All appeals were allowed for statistical purposes with these directions. en-us Thu, 11 Jul 2024 00:00:00 +0530 Tue, 10 Dec 2024 08:58:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762903 The ITAT Mumbai directed the TPO to select fresh comparables dealing specifically in electronic products rather than electrical products, following a chartered engineer's certificate establishing that switch mode power supply (SMPS) is electronic, not electrical. The tribunal emphasized that electronic and electrical products cannot be compared, requiring technical expert certification for proper comparable selection. For the 100% EOU assessee, filters of export turnover exceeding 75% and related party transactions below 25% must be applied. The TPO was also directed to consider capacity utilization in ALP determination. Cash payment additions under section 40A(a) exceeding Rs. 20,000 require further verification with adequate opportunity for the assessee. All appeals were allowed for statistical purposes with these directions. Case-Laws Income Tax Thu, 11 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762903