https://www.taxtmi.com/caselaws?id=460796 The ITAT Hyderabad ruled on transfer pricing adjustments for raw material transfers between Non-SEZ and SEZ units. Both the assessee's methodology excluding 70% of products and the TPO's cherry-picking approach from 11 product families were rejected as inappropriate. The matter was remanded to TPO/AO to determine arm's length price using TNNM method with external/international comparables, allowing 3% tolerance range. The tribunal allowed weighted deduction under section 35(2AB) for entire R&D expenditure including clinical trials, following consistency with previous year's order. Additional depreciation claim was allowed as the AO failed to implement DRP directions without justification. Appeal was partly allowed. en-us Mon, 19 Feb 2024 00:00:00 +0530 Thu, 20 Feb 2025 18:59:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460796 The ITAT Hyderabad ruled on transfer pricing adjustments for raw material transfers between Non-SEZ and SEZ units. Both the assessee's methodology excluding 70% of products and the TPO's cherry-picking approach from 11 product families were rejected as inappropriate. The matter was remanded to TPO/AO to determine arm's length price using TNNM method with external/international comparables, allowing 3% tolerance range. The tribunal allowed weighted deduction under section 35(2AB) for entire R&D expenditure including clinical trials, following consistency with previous year's order. Additional depreciation claim was allowed as the AO failed to implement DRP directions without justification. Appeal was partly allowed. Case-Laws Income Tax Mon, 19 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460796