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ITAT adjudicated transfer pricing dispute involving...
International Guarantee Processing Fees Dispute Resolved: TNMM Method Upheld, Transfer Pricing Adjustment Deleted Based on Consistent Judicial Precedent
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ITAT adjudicated transfer pricing dispute involving international transaction of processing fees for guarantees. The tribunal determined TNMM as the Most Appropriate Method (MAM) for benchmarking, consistent with prior judicial precedent in the assessee's own case. The tribunal noted procedural consistency, highlighting that identical transactions were previously accepted by the Transfer Pricing Officer (TPO) up to AY 2012-13. Applying principles of judicial consistency and finding no material change in underlying facts, the tribunal directed deletion of transfer pricing adjustment. The assessee's appeal was allowed, effectively nullifying the proposed transfer pricing modification and upholding the original transfer pricing methodology.
ITAT adjudicated transfer pricing dispute involving international transaction of processing fees for guarantees. The tribunal determined TNMM as the Most Appropriate Method (MAM) for benchmarking, consistent with prior judicial precedent in the assessee's own case. The tribunal noted procedural consistency, highlighting that identical transactions were previously accepted by the Transfer Pricing Officer (TPO) up to AY 2012-13. Applying principles of judicial consistency and finding no material change in underlying facts, the tribunal directed deletion of transfer pricing adjustment. The assessee's appeal was allowed, effectively nullifying the proposed transfer pricing modification and upholding the original transfer pricing methodology.
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