https://www.taxtmi.com/caselaws?id=770157 ITAT Kolkata allowed assessee's appeal partially regarding transfer pricing adjustments. Tribunal deleted upward adjustments for AMP expenses and royalty payments, finding AMP was not an international transaction based on previous years' decisions. For R&D services and IT support services adjustments, matter was remanded to TPO for fresh comparability analysis. Deduction disallowance under sections 80IB/80IC was deleted as bad debts didn't pertain to eligible units. DTAA benefit issue was remanded to TPO. Disallowance under section 14A couldn't be added back while computing book profits under section 115JB. en-us Tue, 18 Mar 2025 00:00:00 +0530 Wed, 07 May 2025 09:18:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770157 ITAT Kolkata allowed assessee's appeal partially regarding transfer pricing adjustments. Tribunal deleted upward adjustments for AMP expenses and royalty payments, finding AMP was not an international transaction based on previous years' decisions. For R&D services and IT support services adjustments, matter was remanded to TPO for fresh comparability analysis. Deduction disallowance under sections 80IB/80IC was deleted as bad debts didn't pertain to eligible units. DTAA benefit issue was remanded to TPO. Disallowance under section 14A couldn't be added back while computing book profits under section 115JB. Case-Laws Income Tax Tue, 18 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770157