https://www.taxtmi.com/caselaws?id=763324 The ITAT Mumbai ruled in favor of the assessee on three key issues. First, it deleted the TP adjustment on international transactions, finding that the assessee's direct sales to third parties involved higher credit periods (150-180 days) and greater risks compared to sales through associated enterprise TCIPL (5-21 days), justifying the pricing method adopted. Second, it rejected the disallowance under section 14A, noting the assessee had sufficient interest-free funds exceeding investments and the AO failed to justify why the suo moto disallowance was inadequate. Third, it allowed the section 35(2)(ab) deduction claim, clarifying that Form 3CL filing is DSIR's responsibility, not the assessee's, following established HC precedents. en-us Fri, 13 Dec 2024 00:00:00 +0530 Tue, 17 Dec 2024 13:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763324 The ITAT Mumbai ruled in favor of the assessee on three key issues. First, it deleted the TP adjustment on international transactions, finding that the assessee's direct sales to third parties involved higher credit periods (150-180 days) and greater risks compared to sales through associated enterprise TCIPL (5-21 days), justifying the pricing method adopted. Second, it rejected the disallowance under section 14A, noting the assessee had sufficient interest-free funds exceeding investments and the AO failed to justify why the suo moto disallowance was inadequate. Third, it allowed the section 35(2)(ab) deduction claim, clarifying that Form 3CL filing is DSIR's responsibility, not the assessee's, following established HC precedents. Case-Laws Income Tax Fri, 13 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763324