https://www.taxtmi.com/caselaws?id=465057 The ITAT upheld the CIT(A)'s deletion of TP adjustments where the TPO had determined the arm's length price of management and licence/royalty fees at nil. It accepted aggregation of these transactions under TNMM and found no infirmity in the CIT(A)'s reliance on the TPO's report confirming the margins. On the disallowance under sections 36(1)(va)/43B for delayed remittance of employees' PF/ESI contributions, the ITAT held that contributions paid before the due date of filing the return are allowable as deduction. As the assessee had remitted the employees' contribution before the return due date, the disallowance was deleted. The revenue's appeal was dismissed in entirety. en-us Fri, 18 Sep 2020 00:00:00 +0530 Wed, 03 Dec 2025 10:56:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465057 The ITAT upheld the CIT(A)'s deletion of TP adjustments where the TPO had determined the arm's length price of management and licence/royalty fees at nil. It accepted aggregation of these transactions under TNMM and found no infirmity in the CIT(A)'s reliance on the TPO's report confirming the margins. On the disallowance under sections 36(1)(va)/43B for delayed remittance of employees' PF/ESI contributions, the ITAT held that contributions paid before the due date of filing the return are allowable as deduction. As the assessee had remitted the employees' contribution before the return due date, the disallowance was deleted. The revenue's appeal was dismissed in entirety. Case-Laws Income Tax Fri, 18 Sep 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465057