TaxTMI Login
Just a moment...
Press 'Enter' to add multiple search terms. Rules for Better Search
of 
of 
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
of of 
All Highlights
of of All Highlights
Note
Bookmark
Share
Don't have an account? Register Here
of The ITAT allowed the appeal of the assessee, deleting the entire transfer pricing adjustment. The Tribunal held that the TPO erred in rejecting the assessee's internal CUP analysis and in resorting to TNMM; factual findings (including AE financial disclosures and back-to-back invoicing) established the AE as a pass-through with no commission and exact product comparability, making internal CUP the most appropriate method. Alternatively, internal TNMM was also held appropriate. Consequently the TP adjustment was deleted. The Tribunal further directed deletion of the disallowance under s.14A (and Rule 8D computation) by the AO/DRP, since no exempt income arose in the relevant year.
TaxTMI 
TaxTMI 
