ITAT Deletes Brand Promotion TP Adjustment as Issue Was Already Settled in Earlier Years

Hyundai Motor India Ltd. Vs DCIT (ITAT Chennai) The appeal arose from the assessment order dated 23 July 2024 passed under Sections 143(3) and 144C(13) of the Income-tax Act, 1961 for Assessment Year (AY) 2020-21, pursuant to the Dispute Resolution Panel (DRP) directions dated 3 June 2024. The assessee challenged multiple transfer pricing and corporate tax adjustments, including deemed brand promotion adjustment, taxation of government subsidies, depreciation disallowance, disallowance under Section 14A, and levy of interest. The principal transfer pricing dispute concerned an adjustment of â‚...