https://www.taxtmi.com/caselaws?id=310611 The ITAT Mumbai deleted a transfer pricing adjustment for management fees where the TPO made an adhoc determination by estimating 750 hours at INR 3,000 per hour without applying prescribed methods. The Tribunal held that the TPO's unilateral pricing approach was improper as it failed to follow any prescribed transfer pricing methodology and disregarded case facts. Following precedents from Kellogg India, CLSA India, and Firmenich Aromatics cases, the Tribunal rejected the TPO's identical approach and ruled in favor of the assessee. en-us Tue, 15 Nov 2022 00:00:00 +0530 Thu, 02 Nov 2023 19:16:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310611 The ITAT Mumbai deleted a transfer pricing adjustment for management fees where the TPO made an adhoc determination by estimating 750 hours at INR 3,000 per hour without applying prescribed methods. The Tribunal held that the TPO's unilateral pricing approach was improper as it failed to follow any prescribed transfer pricing methodology and disregarded case facts. Following precedents from Kellogg India, CLSA India, and Firmenich Aromatics cases, the Tribunal rejected the TPO's identical approach and ruled in favor of the assessee. Case-Laws Income Tax Tue, 15 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310611