https://www.taxtmi.com/caselaws?id=772375 ITAT Delhi dismissed assessee's challenge to TPO reference, holding technical unit's consultation with TPO valid under sections 92CA and 144B. However, ITAT allowed assessee's appeal on multiple grounds: deleted AMP expense adjustments following HC precedents in Sony Ericson and Maruti Suzuki cases, ruling AMP expenditure not international transactions; deleted CCD re-characterization as equity citing Kirloskar Pneumatic, holding CCDs remain debt until conversion; deleted interest receivable adjustments under CUP method following Kusum Health Care precedent; and set aside DRP findings on UC Singapore services, directing DRP to decide comparables issue afresh as section 144C(8) doesn't permit denovo remand. en-us Fri, 30 May 2025 00:00:00 +0530 Sat, 07 Jun 2025 08:32:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772375 ITAT Delhi dismissed assessee's challenge to TPO reference, holding technical unit's consultation with TPO valid under sections 92CA and 144B. However, ITAT allowed assessee's appeal on multiple grounds: deleted AMP expense adjustments following HC precedents in Sony Ericson and Maruti Suzuki cases, ruling AMP expenditure not international transactions; deleted CCD re-characterization as equity citing Kirloskar Pneumatic, holding CCDs remain debt until conversion; deleted interest receivable adjustments under CUP method following Kusum Health Care precedent; and set aside DRP findings on UC Singapore services, directing DRP to decide comparables issue afresh as section 144C(8) doesn't permit denovo remand. Case-Laws Income Tax Fri, 30 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772375