https://www.taxtmi.com/caselaws?id=207066 ITAT allowed the assessee's appeals. The tribunal upheld TNMM as the appropriate ALP method and found no merit in the TPO's objections, deleting the Rs.4,70,000 disallowance; a 10% discount to the AE was held to be arm's-length. Disallowance under s.40A(2)(b) was rejected as shared-service costs were legitimately for business and fairly allocated. Disallowance under s.40(1)(i) for non-deduction of TDS was deleted since the payments to the foreign AE were not shown to be taxable in India or covered by the make-available clause, and AO failed to establish taxability. en-us Wed, 07 Sep 2011 00:00:00 +0530 Tue, 04 Aug 2026 13:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=207066 ITAT allowed the assessee's appeals. The tribunal upheld TNMM as the appropriate ALP method and found no merit in the TPO's objections, deleting the Rs.4,70,000 disallowance; a 10% discount to the AE was held to be arm's-length. Disallowance under s.40A(2)(b) was rejected as shared-service costs were legitimately for business and fairly allocated. Disallowance under s.40(1)(i) for non-deduction of TDS was deleted since the payments to the foreign AE were not shown to be taxable in India or covered by the make-available clause, and AO failed to establish taxability. Case-Laws Income Tax Wed, 07 Sep 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=207066