TP Adjustment Set Aside Due to Improper Segment Aggregation; Non-Compete Fee Held Revenue

Spectris Technologies P. Ltd. Vs ITO (ITAT Delhi) The Delhi Bench of the Income Tax Appellate Tribunal adjudicated an appeal arising from an order passed under section 250 of the Income-tax Act, 1961, involving two recurring issues in the assessee’s case across multiple assessment years. The assessee, a domestic company engaged in supplying material analysis equipment along with installation, commissioning, and after-sales services, contested transfer pricing adjustments and disallowance of depreciation on non-compete fees. The first issue concerned transfer pricing adjustments relating to s...