https://www.taxtmi.com/caselaws?id=376462 The court allowed condonation of delay in filing/re-filing appeals and disposed of the applications. Regarding the assessment of salaries paid to the Australian AE, the court ruled in favor of the assessee, holding that the salary expenses were not unwarranted. The court found that the CIT(A) correctly applied the Comparable Uncontrolled Prices (CUP) method and rejected the AO's determination of NIL arm's length price. The court emphasized that the TPO cannot interfere with commercial decisions and directed the AO to delete the addition. The court dismissed the appeals, finding no substantial question of law. en-us Tue, 19 Feb 2019 00:00:00 +0530 Fri, 08 Mar 2019 16:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=376462 The court allowed condonation of delay in filing/re-filing appeals and disposed of the applications. Regarding the assessment of salaries paid to the Australian AE, the court ruled in favor of the assessee, holding that the salary expenses were not unwarranted. The court found that the CIT(A) correctly applied the Comparable Uncontrolled Prices (CUP) method and rejected the AO's determination of NIL arm's length price. The court emphasized that the TPO cannot interfere with commercial decisions and directed the AO to delete the addition. The court dismissed the appeals, finding no substantial question of law. Case-Laws Income Tax Tue, 19 Feb 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=376462