https://www.taxtmi.com/caselaws?id=770413 ITAT Delhi allowed the assessee's claim for bad debt deduction under section 36(1)(vii) despite being claimed in a later assessment year, ruling it revenue neutral due to same tax rates. The tribunal permitted 'Data Field Costs' as legitimate business expenditure directly related to market research fees collection. Regarding transfer pricing, ITAT directed inclusion of one comparable company that showed profits, rejecting the persistent loss filter. However, the tribunal rejected the assessee's claim to include written-back provisions as operating income for the associated enterprise segment, finding the general allocation method insufficient to establish direct linkage to AE business operations. en-us Wed, 26 Mar 2025 00:00:00 +0530 Thu, 08 May 2025 14:27:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770413 ITAT Delhi allowed the assessee's claim for bad debt deduction under section 36(1)(vii) despite being claimed in a later assessment year, ruling it revenue neutral due to same tax rates. The tribunal permitted 'Data Field Costs' as legitimate business expenditure directly related to market research fees collection. Regarding transfer pricing, ITAT directed inclusion of one comparable company that showed profits, rejecting the persistent loss filter. However, the tribunal rejected the assessee's claim to include written-back provisions as operating income for the associated enterprise segment, finding the general allocation method insufficient to establish direct linkage to AE business operations. Case-Laws Income Tax Wed, 26 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770413