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ITAT allowed assessee's appeal regarding transfer pricing adjustment on management fees paid to associated enterprise. Assessee benchmarked transaction using entity-level TNMM method, demonstrating arm's length pricing under section 92C(2). TPO rejected assessee's transfer pricing study and applied CUP method, making adjustment despite assessee's compliance with agreed profit margins. ITAT held TPO erred in rejecting TNMM benchmarking merely because assessee did not avail all services under umbrella agreement with AE. Tribunal emphasized TPO can only examine arm's length price of actually availed services, not penalize non-utilization of bundled services. ITAT concluded TNMM was most appropriate method for management fee transactions, rendering TPO's CUP method application inappropriate. Transfer pricing adjustment was deleted, favoring assessee's entity-level profitability analysis over transaction-specific benchmarking for management fees.
ITAT allowed assessee's appeal regarding transfer pricing adjustment on management fees paid to associated enterprise. Assessee benchmarked transaction using entity-level TNMM method, demonstrating arm's length pricing under section 92C(2). TPO rejected assessee's transfer pricing study and applied CUP method, making adjustment despite assessee's compliance with agreed profit margins. ITAT held TPO erred in rejecting TNMM benchmarking merely because assessee did not avail all services under umbrella agreement with AE. Tribunal emphasized TPO can only examine arm's length price of actually availed services, not penalize non-utilization of bundled services. ITAT concluded TNMM was most appropriate method for management fee transactions, rendering TPO's CUP method application inappropriate. Transfer pricing adjustment was deleted, favoring assessee's entity-level profitability analysis over transaction-specific benchmarking for management fees.
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