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The ITAT dismissed the Revenue's appeal and upheld the CIT(A)'s deletion of the transfer pricing adjustment under s. 92CA, confirming that the assessee's use of the CUP method for transactions with its AEs reflected arm's-length pricing. The Tribunal found the TPO/AO had not articulated specific reasons to reject the CUP comparables, had misconstrued facts by inaptly correlating man-month rates to the assessee's purchase transactions, and failed to adduce contrary material rebutting CIT(A)'s factual findings. CIT(A)'s acceptance of published SUNVIN price data and reliance on OECD guidance and precedent were endorsed. Grounds of appeal were dismissed for lack of merit.
The ITAT dismissed the Revenue's appeal and upheld the CIT(A)'s deletion of the transfer pricing adjustment under s. 92CA, confirming that the assessee's use of the CUP method for transactions with its AEs reflected arm's-length pricing. The Tribunal found the TPO/AO had not articulated specific reasons to reject the CUP comparables, had misconstrued facts by inaptly correlating man-month rates to the assessee's purchase transactions, and failed to adduce contrary material rebutting CIT(A)'s factual findings. CIT(A)'s acceptance of published SUNVIN price data and reliance on OECD guidance and precedent were endorsed. Grounds of appeal were dismissed for lack of merit.
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