TP Addition Partly Set Aside for Mechanical Margin Working

Idemitsu Lube India Private Limited Vs DCIT (ITAT Delhi) TP Adjustment on Raw Material Purchase Remanded; Forex Loss on ECB Held Non-Operating — ITAT Delhi The Delhi Bench of the ITAT allowed the appeal of Idemitsu Lube India Pvt. Ltd. for AY 2020-21, granting significant relief on transfer pricing issues relating to purchase of raw material from associated enterprises. On the TP adjustment of ₹4.53 crore, the Tribunal noted that the assessee demonstrated clear computational inconsistencies in margins of comparable companies adopted by the TPO across the TP order, DRP directions, order giv...