https://www.taxtmi.com/caselaws?id=270659 The ITAT partially allowed the appeal, directing the AO to consider the actual management consultancy fees and associated costs, excluding foreign exchange losses, for ALP determination. Additionally, the ITAT instructed the AO to exclude the reimbursement of commission from the TP adjustment as per the DRP's directions. The judgment stressed the significance of detailed documentation and compliance with OECD guidelines in transfer pricing cases. en-us Fri, 30 Oct 2015 00:00:00 +0530 Tue, 12 Jan 2016 00:50:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=270659 The ITAT partially allowed the appeal, directing the AO to consider the actual management consultancy fees and associated costs, excluding foreign exchange losses, for ALP determination. Additionally, the ITAT instructed the AO to exclude the reimbursement of commission from the TP adjustment as per the DRP's directions. The judgment stressed the significance of detailed documentation and compliance with OECD guidelines in transfer pricing cases. Case-Laws Income Tax Fri, 30 Oct 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=270659