https://www.taxtmi.com/caselaws?id=776558 The ITAT Mumbai directed exclusion of MPS, Manipal, Integra, and Wizard from the comparable set for TP adjustments, while including Bhilwara and UBM for respective service segments, and ordered recomputation accordingly. For the engineering services segment, the AO/TPO was instructed to follow the Tribunal's earlier ruling for AY 2017-18. Regarding the manufacturing segment, the Tribunal accepted the assessee's economic adjustments under Rule 10B(1)(e) for low capacity utilization and remanded the matter for reconsideration. No disallowance under section 14A was warranted as the assessee earned no exempt income. The addition under section 36(1)(va) for delayed employee contribution deposit was upheld. The disallowance under section 40(a)(i) for TDS on salary paid to a foreign employee was set aside, as salary payments were subject to section 192 and not section 195, with no violation of tax provisions established. en-us Wed, 28 May 2025 00:00:00 +0530 Wed, 13 Aug 2025 07:27:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776558 The ITAT Mumbai directed exclusion of MPS, Manipal, Integra, and Wizard from the comparable set for TP adjustments, while including Bhilwara and UBM for respective service segments, and ordered recomputation accordingly. For the engineering services segment, the AO/TPO was instructed to follow the Tribunal's earlier ruling for AY 2017-18. Regarding the manufacturing segment, the Tribunal accepted the assessee's economic adjustments under Rule 10B(1)(e) for low capacity utilization and remanded the matter for reconsideration. No disallowance under section 14A was warranted as the assessee earned no exempt income. The addition under section 36(1)(va) for delayed employee contribution deposit was upheld. The disallowance under section 40(a)(i) for TDS on salary paid to a foreign employee was set aside, as salary payments were subject to section 192 and not section 195, with no violation of tax provisions established. Case-Laws Income Tax Wed, 28 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776558