https://www.taxtmi.com/caselaws?id=437348 The ITAT Kolkata ruled in favor of the assessee regarding TP adjustment on management fee payments to associated enterprise. The TPO's rejection of assessee's TNMM benchmarking and adoption of CUP method was held improper as TPO failed to identify comparable uncontrolled transactions required for CUP application. The assessee had properly benchmarked the transaction using TNMM with eight comparable companies, and TPO provided no justification for discarding this method. The court noted management fee expenses were accepted by department in previous years for similar services. Additionally, the disallowance under section 14A was deleted as investments were in debt mutual funds yielding taxable income, not exempt income. Appeal by revenue dismissed. en-us Thu, 27 Apr 2023 00:00:00 +0530 Mon, 17 Mar 2025 10:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=437348 The ITAT Kolkata ruled in favor of the assessee regarding TP adjustment on management fee payments to associated enterprise. The TPO's rejection of assessee's TNMM benchmarking and adoption of CUP method was held improper as TPO failed to identify comparable uncontrolled transactions required for CUP application. The assessee had properly benchmarked the transaction using TNMM with eight comparable companies, and TPO provided no justification for discarding this method. The court noted management fee expenses were accepted by department in previous years for similar services. Additionally, the disallowance under section 14A was deleted as investments were in debt mutual funds yielding taxable income, not exempt income. Appeal by revenue dismissed. Case-Laws Income Tax Thu, 27 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=437348