https://www.taxtmi.com/caselaws?id=462588 ITAT Chennai allowed assessee's appeal regarding transfer pricing adjustments. TPO was directed to grant differential adjustment for basic customs duty since assessee imported 85% of raw materials from associated enterprise compared to 16.10% by comparable companies, significantly impacting margins due to non-cenvatable customs duty portion. Tribunal followed its own precedent from AY 2011-12 allowing similar adjustment. Additionally, TPO was directed to restrict upward adjustment to international transaction value of Rs.481.47 Lacs rather than entity-level computation including both associated and non-associated transactions. en-us Wed, 18 May 2022 00:00:00 +0530 Wed, 02 Jul 2025 19:03:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462588 ITAT Chennai allowed assessee's appeal regarding transfer pricing adjustments. TPO was directed to grant differential adjustment for basic customs duty since assessee imported 85% of raw materials from associated enterprise compared to 16.10% by comparable companies, significantly impacting margins due to non-cenvatable customs duty portion. Tribunal followed its own precedent from AY 2011-12 allowing similar adjustment. Additionally, TPO was directed to restrict upward adjustment to international transaction value of Rs.481.47 Lacs rather than entity-level computation including both associated and non-associated transactions. Case-Laws Income Tax Wed, 18 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462588