https://www.taxtmi.com/caselaws?id=463415 ITAT BANGALORE - AT remitted multiple transfer pricing and tax issues to the AO/TPO for fresh decision after affording the assessee opportunity of hearing. The tribunal directed reassessment of capacity-utilisation, customs duty, air-freight and foreign-exchange adjustments; allowed that under-utilisation adjustment subsumes any separate depreciation claim; ordered working-capital adjustment as per actuals; upheld the deductibility of warranty provisions; and directed fresh examination of royalty/technology payments and numerous challenged comparables (including specified software/ITES entities) with instructions to obtain necessary data where public information is lacking. Several exclusions were set aside and comparables to be reconsidered. en-us Mon, 06 Feb 2023 00:00:00 +0530 Fri, 29 Aug 2025 18:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463415 ITAT BANGALORE - AT remitted multiple transfer pricing and tax issues to the AO/TPO for fresh decision after affording the assessee opportunity of hearing. The tribunal directed reassessment of capacity-utilisation, customs duty, air-freight and foreign-exchange adjustments; allowed that under-utilisation adjustment subsumes any separate depreciation claim; ordered working-capital adjustment as per actuals; upheld the deductibility of warranty provisions; and directed fresh examination of royalty/technology payments and numerous challenged comparables (including specified software/ITES entities) with instructions to obtain necessary data where public information is lacking. Several exclusions were set aside and comparables to be reconsidered. Case-Laws Income Tax Mon, 06 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463415