Summary
- The ITAT Ahmedabad has deleted a Rs.19,18,458 royalty adjustment for Kloeckner Desma Machinery Private Ltd., ruling that the TPO failed to establish a reliable comparable for export transactions.
- The Tribunal remanded the Rs.67,77,799 commission adjustment back to the TPO for fresh adjudication, citing insufficient comparability in the agreements used by the TPO.
- For AY 2013-14, similar findings led to the deletion of a Rs.19,67,641 royalty adjustment and restoration of a Rs.37,07,151 commission issue for further examination.
- This decision underscores the importance of functional comparability in transfer pricing and could impact future assessments involving international transactions.
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