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        Case ID :
        Income Tax

        The ITAT set aside the transfer pricing addition and related...

        Transfer pricing addition and s.37 disallowance set aside; ALP to be computed using TNMM corroborative benchmarking

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                The ITAT set aside the transfer pricing addition and related disallowance under s.37, rejecting the Revenue's determination of NIL ALP for intra-group services. The Tribunal overturned the TPO/DRP finding that the Taxpayer failed the need, purpose, rendition and benefit tests, held the Taxpayer's corroborative benchmarking (TNMM with the Indian entity as tested party and operating profit/sales as PLI) to be admissible, and directed the TPO to compute the ALP in accordance with that corroborative benchmarking after verifying the PLI computation. The ITAT declined the Revenue's submission equating the TPO approach to the "Other Method" and dismissed the AO/DRP directions disallowing the payments.
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