https://www.taxtmi.com/caselaws?id=215230 The ITAT Delhi upheld the assessee's claim regarding management service fees and coordination costs, rejecting the TPO's CUP method in favor of the TNMM method for transfer pricing. The tribunal found no justification for additions since the assessee provided sufficient evidence of services rendered and benefits received. The assessee's net margin of 26% exceeded the 8% average of comparables, supporting the appropriateness of entity-level benchmarking. Disallowances under section 40(a) were remanded to the AO for fresh consideration. The tribunal dismissed the challenge to interest levied under section 234B, affirming its mandatory nature and consequential effect. en-us Fri, 08 Jun 2012 00:00:00 +0530 Thu, 14 Aug 2025 13:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=215230 The ITAT Delhi upheld the assessee's claim regarding management service fees and coordination costs, rejecting the TPO's CUP method in favor of the TNMM method for transfer pricing. The tribunal found no justification for additions since the assessee provided sufficient evidence of services rendered and benefits received. The assessee's net margin of 26% exceeded the 8% average of comparables, supporting the appropriateness of entity-level benchmarking. Disallowances under section 40(a) were remanded to the AO for fresh consideration. The tribunal dismissed the challenge to interest levied under section 234B, affirming its mandatory nature and consequential effect. Case-Laws Income Tax Fri, 08 Jun 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=215230