https://www.taxtmi.com/caselaws?id=754204 ITAT Mumbai allowed assessee's appeal regarding transfer pricing adjustments on brokerage commission from associated enterprises. Court held TNMM method appropriate over CUP method for benchmarking transactions, as TPO failed to specify comparables or justify CUP selection. Royalty payments to Netherlands entity for brand usage were upheld at 1% domestic and 2% export sales using TNMM method, following previous years' decisions. Indirect cost reimbursements for group expenses were allowed as TPO made adhoc additions without applying prescribed methods. Outstanding securities transaction tax addition was deleted. TDS disallowances under sections 40(a)(ia) and 195 were also deleted, with court ruling no TDS required for exchange transaction charges. en-us Wed, 22 May 2024 00:00:00 +0530 Tue, 18 Jun 2024 10:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754204 ITAT Mumbai allowed assessee's appeal regarding transfer pricing adjustments on brokerage commission from associated enterprises. Court held TNMM method appropriate over CUP method for benchmarking transactions, as TPO failed to specify comparables or justify CUP selection. Royalty payments to Netherlands entity for brand usage were upheld at 1% domestic and 2% export sales using TNMM method, following previous years' decisions. Indirect cost reimbursements for group expenses were allowed as TPO made adhoc additions without applying prescribed methods. Outstanding securities transaction tax addition was deleted. TDS disallowances under sections 40(a)(ia) and 195 were also deleted, with court ruling no TDS required for exchange transaction charges. Case-Laws Income Tax Wed, 22 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754204