https://www.taxtmi.com/caselaws?id=751072 The ITAT Mumbai upheld CIT(A)'s deletion of transfer pricing adjustment where assessee's profit level indicator (PLI) of 6.12% exceeded comparable companies' average PLI of 5.41% under Transactional Net Margin Method (TNMM). Despite AO's objection to inclusion of low-margin comparables (1-2%), ITAT found no functional incomparability established. The assessee had adopted TNMM as most appropriate method in subsequent years, validating CIT(A)'s approach. Revenue's challenge regarding fresh comparables introduced before CIT(A) was rejected as functional comparability remained intact. No arm's length price adjustment warranted when assessee's margins exceeded comparable range. en-us Thu, 29 Feb 2024 00:00:00 +0530 Sat, 06 Apr 2024 10:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751072 The ITAT Mumbai upheld CIT(A)'s deletion of transfer pricing adjustment where assessee's profit level indicator (PLI) of 6.12% exceeded comparable companies' average PLI of 5.41% under Transactional Net Margin Method (TNMM). Despite AO's objection to inclusion of low-margin comparables (1-2%), ITAT found no functional incomparability established. The assessee had adopted TNMM as most appropriate method in subsequent years, validating CIT(A)'s approach. Revenue's challenge regarding fresh comparables introduced before CIT(A) was rejected as functional comparability remained intact. No arm's length price adjustment warranted when assessee's margins exceeded comparable range. Case-Laws Income Tax Thu, 29 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751072