https://www.taxtmi.com/caselaws?id=310648 ITAT Mumbai ruled in favor of the assessee regarding transfer pricing adjustment of management fees paid to associated enterprise. The court held that the Transfer Pricing Officer made an adhoc unilateral estimation by assuming 750 hours of service at INR 3,000 per hour without applying prescribed methods under transfer pricing regulations. The Tribunal deleted the addition, finding that TPO failed to follow proper methodology and disregarded case facts. The decision relied on coordinate bench precedents including assessee's own earlier case and Kellogg India matter. Assessee's appeal was allowed. en-us Thu, 12 Jan 2023 00:00:00 +0530 Sat, 04 Nov 2023 09:17:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310648 ITAT Mumbai ruled in favor of the assessee regarding transfer pricing adjustment of management fees paid to associated enterprise. The court held that the Transfer Pricing Officer made an adhoc unilateral estimation by assuming 750 hours of service at INR 3,000 per hour without applying prescribed methods under transfer pricing regulations. The Tribunal deleted the addition, finding that TPO failed to follow proper methodology and disregarded case facts. The decision relied on coordinate bench precedents including assessee's own earlier case and Kellogg India matter. Assessee's appeal was allowed. Case-Laws Income Tax Thu, 12 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310648