https://www.taxtmi.com/caselaws?id=311249 ITAT Mumbai allowed the assessee's appeal on multiple grounds. The tribunal deleted transfer pricing adjustments totaling Rs. 3,66,71,462/- for Global Client Management Fee payments, noting that TPO in subsequent years accepted similar transactions and made only ad-hoc adjustments without following prescribed methods under section 92C(1). The tribunal directed TPO to accept the foreign associated enterprise as tested party for benchmarking analysis, maintaining consistency with subsequent assessment years. Section 14A disallowance was deleted as no exempt income was received during the relevant year. Addition under section 2(22)(e) for deemed dividend was also deleted since the loans were interest-bearing advances for business purposes, repaid with 12% interest. en-us Fri, 01 Apr 2022 00:00:00 +0530 Thu, 14 Dec 2023 20:04:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311249 ITAT Mumbai allowed the assessee's appeal on multiple grounds. The tribunal deleted transfer pricing adjustments totaling Rs. 3,66,71,462/- for Global Client Management Fee payments, noting that TPO in subsequent years accepted similar transactions and made only ad-hoc adjustments without following prescribed methods under section 92C(1). The tribunal directed TPO to accept the foreign associated enterprise as tested party for benchmarking analysis, maintaining consistency with subsequent assessment years. Section 14A disallowance was deleted as no exempt income was received during the relevant year. Addition under section 2(22)(e) for deemed dividend was also deleted since the loans were interest-bearing advances for business purposes, repaid with 12% interest. Case-Laws Income Tax Fri, 01 Apr 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311249