https://www.taxtmi.com/caselaws?id=461146 ITAT Mumbai ruled on multiple transfer pricing and tax issues. The tribunal allowed technical know-how fees adjustment based on parity with previous assessment year, rejecting TPO's need-benefit test approach. Employee cost reimbursement matter was restored to AO/TPO for fresh consideration with additional evidence. Section 40(a)(i) disallowance for legal services was remanded to verify tax payment by service provider to avoid double taxation. Depreciation on fixed assets was allowed following previous year's precedent. Foreign exchange gains were treated as operational income based on HC precedent. Provisions written back were considered operating income per Bombay HC ruling. Revenue's appeal on DRP's deletion of TP adjustment was dismissed as no fresh evidence was demonstrated. en-us Mon, 08 Apr 2024 00:00:00 +0530 Mon, 17 Mar 2025 18:34:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461146 ITAT Mumbai ruled on multiple transfer pricing and tax issues. The tribunal allowed technical know-how fees adjustment based on parity with previous assessment year, rejecting TPO's need-benefit test approach. Employee cost reimbursement matter was restored to AO/TPO for fresh consideration with additional evidence. Section 40(a)(i) disallowance for legal services was remanded to verify tax payment by service provider to avoid double taxation. Depreciation on fixed assets was allowed following previous year's precedent. Foreign exchange gains were treated as operational income based on HC precedent. Provisions written back were considered operating income per Bombay HC ruling. Revenue's appeal on DRP's deletion of TP adjustment was dismissed as no fresh evidence was demonstrated. Case-Laws Income Tax Mon, 08 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461146