https://www.taxtmi.com/highlights?id=93548 The ITAT directed deletion of transfer pricing adjustments relating to AMP expenditure and Asian regional headquarter allocations, held warranty reimbursements were pass-through with no markup, and upheld no merit in adjustments for design and development charges. Royalty adjustments were fixed per prior years (resulting in an Rs. 18,70,787 adjustment for 2001-12); royalties in specified assessment years were held at arm's length or restored to the AO for determination in light of a CA certificate. Expatriate salaries were allowed as business expenditure u/s 37(1). Section 80JJAA relief was allowed with retrospective effect as clarificatory. Refund claim for excess DDT was dismissed. Disallowances under s.40(a)(ia), repairs and maintenance, and penalty u/s 271(1)(c) were deleted. en-us Sat, 25 Oct 2025 09:00:56 +0530 Sat, 25 Oct 2025 09:00:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=93548 The ITAT directed deletion of transfer pricing adjustments relating to AMP expenditure and Asian regional headquarter allocations, held warranty reimbursements were pass-through with no markup, and upheld no merit in adjustments for design and development charges. Royalty adjustments were fixed per prior years (resulting in an Rs. 18,70,787 adjustment for 2001-12); royalties in specified assessment years were held at arm's length or restored to the AO for determination in light of a CA certificate. Expatriate salaries were allowed as business expenditure u/s 37(1). Section 80JJAA relief was allowed with retrospective effect as clarificatory. Refund claim for excess DDT was dismissed. Disallowances under s.40(a)(ia), repairs and maintenance, and penalty u/s 271(1)(c) were deleted. Highlights Income Tax Sat, 25 Oct 2025 09:00:56 +0530 https://www.taxtmi.com/highlights?id=93548