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ITAT held that the DRP correctly sustained the TPO's rejection of the TNMM for charges to AEs and the invocation of the "other method" for determining ALP of "other support services," but found the adhoc 50% disallowance unjustified. The Tribunal ruled that the TPO should have computed ALP in accordance with statutory procedure rather than by arbitrary percentage reduction, and that the benchmarking fixed by the DRP lacked conformity with applicable provisions. The matter is remitted to the AO for fresh computation of ALP after affording the assessee an opportunity to furnish requisite details and evidence. Assessee's appeal is allowed for statistical purposes.
ITAT held that the DRP correctly sustained the TPO's rejection of the TNMM for charges to AEs and the invocation of the "other method" for determining ALP of "other support services," but found the adhoc 50% disallowance unjustified. The Tribunal ruled that the TPO should have computed ALP in accordance with statutory procedure rather than by arbitrary percentage reduction, and that the benchmarking fixed by the DRP lacked conformity with applicable provisions. The matter is remitted to the AO for fresh computation of ALP after affording the assessee an opportunity to furnish requisite details and evidence. Assessee's appeal is allowed for statistical purposes.
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