https://www.taxtmi.com/caselaws?id=768040 ITAT Delhi dismissed Revenue's appeal regarding transfer pricing adjustments. The tribunal upheld validity of assessment order despite lack of recorded reasons for TPO referral, following Aztec Software precedent. However, ITAT allowed assessee's grounds on intra-group services and mark-up on fixed asset purchases, directing deletion of ALP adjustments as no material distinguishing features existed compared to previous year's favorable decision. For royalty payments, ITAT rejected Department's appeal, citing EKL Appliances precedent against need-benefit test and Magneti Marelli ruling preventing segregation of aggregated transactions benchmarked under TNMM. en-us Wed, 26 Mar 2025 00:00:00 +0530 Sat, 29 Mar 2025 08:15:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768040 ITAT Delhi dismissed Revenue's appeal regarding transfer pricing adjustments. The tribunal upheld validity of assessment order despite lack of recorded reasons for TPO referral, following Aztec Software precedent. However, ITAT allowed assessee's grounds on intra-group services and mark-up on fixed asset purchases, directing deletion of ALP adjustments as no material distinguishing features existed compared to previous year's favorable decision. For royalty payments, ITAT rejected Department's appeal, citing EKL Appliances precedent against need-benefit test and Magneti Marelli ruling preventing segregation of aggregated transactions benchmarked under TNMM. Case-Laws Income Tax Wed, 26 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768040