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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.
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.
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