https://www.taxtmi.com/caselaws?id=776017 The ITAT Delhi held that the TPO's allocation of indirect expenses based on export revenue proportion was flawed, as these expenses were also attributable to an abandoned project. The assessee's method of considering actual expenses for trading activity was accepted. Since the assessee had already disallowed the entire indirect expenses in income computation, no further adjustment was warranted. The tribunal directed the TPO to accept the assessee's operating margin at 6.24%, resulting in no transfer pricing adjustment for the trading activity. The assessee's grounds were allowed. en-us Wed, 30 Jul 2025 00:00:00 +0530 Thu, 31 Jul 2025 13:25:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776017 The ITAT Delhi held that the TPO's allocation of indirect expenses based on export revenue proportion was flawed, as these expenses were also attributable to an abandoned project. The assessee's method of considering actual expenses for trading activity was accepted. Since the assessee had already disallowed the entire indirect expenses in income computation, no further adjustment was warranted. The tribunal directed the TPO to accept the assessee's operating margin at 6.24%, resulting in no transfer pricing adjustment for the trading activity. The assessee's grounds were allowed. Case-Laws Income Tax Wed, 30 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776017