Free-of-Cost Testing Assets Not Taxable Under Section 28(iv): ITAT Bangalore

AMD India Private Ltd. Vs DCIT (ITAT Bangalore)

12% Mark-Up on Free Assets Deleted as No Taxable Benefit Exists; Large Turnover and Functional Differences Justify Exclusion of Comparables; Provisions for Bad Debts Treated as Operating Expense in TP Analysis; Transfer Pricing Adjustment Nullified; Revenue Appeal Dismissed

The case involved cross appeals by the assessee and the Revenue for Assessment Year 2013–14 against the appellate order dated 31.07.2024. The assessee is engaged in providing software development services relating to semiconductor design a

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