https://www.taxtmi.com/caselaws?id=777421 ITAT allowed the assessee's TP challenges in part: it directed exclusion of two identified comparables when computing the comparable margin, resulting in the assessee's margin of 11.88% falling within the permissible ±3% band and relieving the adjustment; directed exclusion of a specified comparable in the contract R&D analysis; confirmed that intra-group services and advertisement/marketing/promotions are not chargeable international transactions and deleted related adjustments. Matters involving double disallowance of interest and deemed income, disputed interest u/s 234A/234B, and short grant of TDS/TCS credit were restored to the AO for fresh consideration after hearing. The leased-rental position was upheld consistent with prior bench rulings. en-us Tue, 26 Aug 2025 00:00:00 +0530 Fri, 29 Aug 2025 08:56:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777421 ITAT allowed the assessee's TP challenges in part: it directed exclusion of two identified comparables when computing the comparable margin, resulting in the assessee's margin of 11.88% falling within the permissible ±3% band and relieving the adjustment; directed exclusion of a specified comparable in the contract R&D analysis; confirmed that intra-group services and advertisement/marketing/promotions are not chargeable international transactions and deleted related adjustments. Matters involving double disallowance of interest and deemed income, disputed interest u/s 234A/234B, and short grant of TDS/TCS credit were restored to the AO for fresh consideration after hearing. The leased-rental position was upheld consistent with prior bench rulings. Case-Laws Income Tax Tue, 26 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777421