https://www.taxtmi.com/caselaws?id=464015 ITAT upheld that the TPO's selection of comparables and rejection of the assessee's primary and secondary ALP analyses was not sustainable and, in view of a prior Tribunal finding, rejected the impugned transfer pricing adjustment. The Tribunal remitted the allowability of indirect revenue expenses (legal, advertising, commissions) to the AO for fresh adjudication. It held Rule 8D(2) inapplicable for Rule 14A computation but directed a 1% administrative disallowance of dividend income under section 14A; related book-profit disallowance under section 115JB was partly allowed. The AO was also directed to verify carry-forward unabsorbed depreciation. en-us Fri, 30 Sep 2022 00:00:00 +0530 Thu, 25 Sep 2025 16:06:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464015 ITAT upheld that the TPO's selection of comparables and rejection of the assessee's primary and secondary ALP analyses was not sustainable and, in view of a prior Tribunal finding, rejected the impugned transfer pricing adjustment. The Tribunal remitted the allowability of indirect revenue expenses (legal, advertising, commissions) to the AO for fresh adjudication. It held Rule 8D(2) inapplicable for Rule 14A computation but directed a 1% administrative disallowance of dividend income under section 14A; related book-profit disallowance under section 115JB was partly allowed. The AO was also directed to verify carry-forward unabsorbed depreciation. Case-Laws Income Tax Fri, 30 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464015