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In transfer pricing for sale of goods to associated enterprises, the Tribunal accepted TNMM at entity level and rejected the internal cost plus method because earlier coordinate bench decisions on identical facts had already approved TNMM, and no material factual change was shown; the transfer pricing adjustment was deleted. On reversal of provisions, it held that amounts already disallowed when created cannot be taxed again on reversal, but remitted the issue to the Assessing Officer for verification of the claimed accounting mismatch and reconciliation. For short grant of TDS/TCS credit, it directed factual verification from Form 26AS, AIS and supporting records, with due credit to be allowed in accordance with law.
In transfer pricing for sale of goods to associated enterprises, the Tribunal accepted TNMM at entity level and rejected the internal cost plus method because earlier coordinate bench decisions on identical facts had already approved TNMM, and no material factual change was shown; the transfer pricing adjustment was deleted. On reversal of provisions, it held that amounts already disallowed when created cannot be taxed again on reversal, but remitted the issue to the Assessing Officer for verification of the claimed accounting mismatch and reconciliation. For short grant of TDS/TCS credit, it directed factual verification from Form 26AS, AIS and supporting records, with due credit to be allowed in accordance with law.
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