ITAT Partly Allows TP Appeal, Revises Comparable Selection for ALP Determination

Honda R & D (India) Private Limited Vs Additional/Joint/Deputy/ACIT/ITO (ITAT Delhi) In this case, the assessee challenged the final assessment order for Assessment Year 2017-18, which included transfer pricing adjustments, disallowance of depreciation on computer software, and disallowance under Section 40(a)(ia) relating to international travel expenses. The assessment arose after the Transfer Pricing Officer (TPO) proposed an adjustment in respect of international transactions involving the provision of basic market research and testing services to associated enterprises. The final asse...