https://www.taxtmi.com/caselaws?id=780137 ITAT CHENNAI - AT allowed the appeals. Provision for the customer loyalty program was held allowable relying on the assessee's earlier case; issues for AYs 2013-14 and 2014-15 were allowed. Disallowance under section 14A was set aside because the AO failed to record requisite satisfaction. Transfer-pricing adjustments related to claims under section 80IC were reversed: TPO/DRP failed to identify specific documentation defects, ignored comparability differences (product mix, processes, market dynamics), and benchmarked inter-unit semi-finished transfers against third-party finished-goods margins. Overall TP adjustments were not sustained. en-us Fri, 19 Sep 2025 00:00:00 +0530 Fri, 24 Oct 2025 09:18:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780137 ITAT CHENNAI - AT allowed the appeals. Provision for the customer loyalty program was held allowable relying on the assessee's earlier case; issues for AYs 2013-14 and 2014-15 were allowed. Disallowance under section 14A was set aside because the AO failed to record requisite satisfaction. Transfer-pricing adjustments related to claims under section 80IC were reversed: TPO/DRP failed to identify specific documentation defects, ignored comparability differences (product mix, processes, market dynamics), and benchmarked inter-unit semi-finished transfers against third-party finished-goods margins. Overall TP adjustments were not sustained. Case-Laws Income Tax Fri, 19 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780137