https://www.taxtmi.com/caselaws?id=783125 ITAT partly allowed assessee's appeal and upheld CIT(A)'s relief on key issues. It held that a separate TP benchmarking for royalty was impermissible when TNMM was accepted for other international transactions; the assessee's TNMM-based ALP for royalty was directed to be accepted. Exemption u/s 10AA was sustained, holding that for A.Y. 2018-19 timely filing u/s 139(1) was not a mandatory condition and the marginal delay due to portal glitches could not defeat the claim. Deduction u/s 80JJAA, disallowed by CPC for delayed return, was also allowed. Disallowance u/s 14A as made by AO was upheld, but its addition to book profit u/s 115JB was disallowed. Issues on s.35(2AB), double taxation of LTCG and interest u/s 234C were remanded to AO. en-us Thu, 04 Dec 2025 00:00:00 +0530 Mon, 15 Dec 2025 17:47:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783125 ITAT partly allowed assessee's appeal and upheld CIT(A)'s relief on key issues. It held that a separate TP benchmarking for royalty was impermissible when TNMM was accepted for other international transactions; the assessee's TNMM-based ALP for royalty was directed to be accepted. Exemption u/s 10AA was sustained, holding that for A.Y. 2018-19 timely filing u/s 139(1) was not a mandatory condition and the marginal delay due to portal glitches could not defeat the claim. Deduction u/s 80JJAA, disallowed by CPC for delayed return, was also allowed. Disallowance u/s 14A as made by AO was upheld, but its addition to book profit u/s 115JB was disallowed. Issues on s.35(2AB), double taxation of LTCG and interest u/s 234C were remanded to AO. Case-Laws Income Tax Thu, 04 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783125