https://www.taxtmi.com/caselaws?id=344121 The Tribunal allowed the appeal, directing the deletion of the upward adjustment of Rs. 1,51,83,140 for management fees. It found that services were rendered by SEI-F, contrary to the TPO's determination of a NIL arm's length price (ALP). The Tribunal criticized the TPO's rejection of the Transactional Net Margin Method (TNMM) without adopting an appropriate alternative method. It emphasized the importance of proper documentation and consistent application of ALP determination methods, rejecting the conclusions of the TPO and CIT(A) due to insufficient evidence. en-us Wed, 31 May 2017 00:00:00 +0530 Fri, 10 Jul 2026 10:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=344121 The Tribunal allowed the appeal, directing the deletion of the upward adjustment of Rs. 1,51,83,140 for management fees. It found that services were rendered by SEI-F, contrary to the TPO's determination of a NIL arm's length price (ALP). The Tribunal criticized the TPO's rejection of the Transactional Net Margin Method (TNMM) without adopting an appropriate alternative method. It emphasized the importance of proper documentation and consistent application of ALP determination methods, rejecting the conclusions of the TPO and CIT(A) due to insufficient evidence. Case-Laws Income Tax Wed, 31 May 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=344121