https://www.taxtmi.com/caselaws?id=310660 The ITAT Pune reversed the transfer pricing adjustment made by authorities who determined the arm's length price of intra-group marketing and administrative services at nil using the CUP method. The assessee had applied TNMM method aggregating all international transactions including raw material purchases and intra-group services. Following precedent from the assessee's own case for AY 2009-10, the Tribunal held that where genuineness of payments to associated enterprises was not disputed and services were provided at cost, no adjustment could be made applying benefit test. The Tribunal directed authorities to apply TNMM method for benchmarking transactions on aggregate basis, allowing the assessee's appeal. en-us Fri, 07 Jun 2019 00:00:00 +0530 Sat, 04 Nov 2023 22:14:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310660 The ITAT Pune reversed the transfer pricing adjustment made by authorities who determined the arm's length price of intra-group marketing and administrative services at nil using the CUP method. The assessee had applied TNMM method aggregating all international transactions including raw material purchases and intra-group services. Following precedent from the assessee's own case for AY 2009-10, the Tribunal held that where genuineness of payments to associated enterprises was not disputed and services were provided at cost, no adjustment could be made applying benefit test. The Tribunal directed authorities to apply TNMM method for benchmarking transactions on aggregate basis, allowing the assessee's appeal. Case-Laws Income Tax Fri, 07 Jun 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310660