Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Transfer pricing adjustment on purchases from an associated enterprise was disputed, with the assessee benchmarking specified domestic transactions under the CUP method. Since CUP was accepted as the most appropriate method and the assessee's documentation supported that its pricing was at arm's length, the TPO/AO lacked justification to substitute and adjust ALP. The ±5% tolerance was held to be merely a post-determination variation band, and where the charged price falls within that range, no adjustment arises. Consequently, the impugned ALP adjustment on AE purchases was deleted and the appeal was allowed. - ITAT
Transfer pricing adjustment on purchases from an associated enterprise was disputed, with the assessee benchmarking specified domestic transactions under the CUP method. Since CUP was accepted as the most appropriate method and the assessee's documentation supported that its pricing was at arm's length, the TPO/AO lacked justification to substitute and adjust ALP. The ±5% tolerance was held to be merely a post-determination variation band, and where the charged price falls within that range, no adjustment arises. Consequently, the impugned ALP adjustment on AE purchases was deleted and the appeal was allowed. - ITAT
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