ITAT allowed the appeal and set aside the orders of the lower...

ITAT allowed the appeal and set aside the orders of the lower authorities, directing the AO to delete the impugned addition arising from a downward TP adjustment in respect of global account management charges (GAM). The Tribunal held that the appellant reasonably quantified benefit from services rendered by its associated enterprise and that aggregation and application of TNMM to the GAM charges was appropriate; the TPO erred in excluding GAM for separate benchmarking. On the facts, the GAM payments were inextricably linked to the appellant's core business and could not be segregated for independent benchmarking, resulting in a decision in favour of the appellant.