https://www.taxtmi.com/caselaws?id=448013 ITAT Mumbai set aside transfer pricing adjustment in manufacturing segment, directing TPO/AO to re-compute arm's length price using TNM method instead of CUP method, consistent with earlier year's approach. Regarding technical support services fees, tribunal excluded Excel Infoways Ltd as comparable due to closure of ITES segment and fluctuating margins, and rejected Hartron Communications Ltd for extraordinary profits and functional dissimilarity. Assessee's appeal was allowed. en-us Tue, 31 Oct 2023 00:00:00 +0530 Wed, 10 Jan 2024 09:20:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448013 ITAT Mumbai set aside transfer pricing adjustment in manufacturing segment, directing TPO/AO to re-compute arm's length price using TNM method instead of CUP method, consistent with earlier year's approach. Regarding technical support services fees, tribunal excluded Excel Infoways Ltd as comparable due to closure of ITES segment and fluctuating margins, and rejected Hartron Communications Ltd for extraordinary profits and functional dissimilarity. Assessee's appeal was allowed. Case-Laws Income Tax Tue, 31 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448013