https://www.taxtmi.com/caselaws?id=752291 Transfer pricing adjustments on management consultancy fees, software licence fees, regional coordination services, and IT cost allocations were deleted because the assessee's benchmarking was supported by internal CUP, TNMM comparables, or earlier year reasoning, and the record did not justify ad hoc substitution or unsupported comparable exclusion. The Tribunal reiterated that the prescribed transfer pricing method must be applied through a proper comparability analysis, and where internal comparables or accepted comparables support the assessee's position, the adjustment cannot stand. The claim for short-grant of interest under section 244A was also allowed, as refund interest is payable up to the date of actual receipt of the refund order or instrument. en-us Fri, 03 May 2024 00:00:00 +0530 Mon, 06 May 2024 20:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752291 Transfer pricing adjustments on management consultancy fees, software licence fees, regional coordination services, and IT cost allocations were deleted because the assessee's benchmarking was supported by internal CUP, TNMM comparables, or earlier year reasoning, and the record did not justify ad hoc substitution or unsupported comparable exclusion. The Tribunal reiterated that the prescribed transfer pricing method must be applied through a proper comparability analysis, and where internal comparables or accepted comparables support the assessee's position, the adjustment cannot stand. The claim for short-grant of interest under section 244A was also allowed, as refund interest is payable up to the date of actual receipt of the refund order or instrument. Case-Laws Income Tax Fri, 03 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752291