https://www.taxtmi.com/caselaws?id=755054 ITAT Mumbai ruled on transfer pricing adjustments for equity broking services. For non-DVP segment transactions, the tribunal applied CUP method comparing weighted average commission rates between associated enterprises and third-party FII clients, determining ALP brokerage rate at 0.41% after adjusting for sales/marketing functions. Port fee charges were accepted at cost plus 25% markup as per agreement rather than CIT(A)'s 15% markup. Administrative support services required no adjustment as assessee's 17.2% margin exceeded arm's length price of 13.67%. Program trades adjustment was rejected as these were third-party independent transactions. Section 14A disallowance was limited to suo-moto amount offered by assessee since Rule 8D wasn't applicable for AY 2002-03 and sufficient interest-free funds existed. en-us Mon, 10 Jun 2024 00:00:00 +0530 Wed, 03 Jul 2024 18:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755054 ITAT Mumbai ruled on transfer pricing adjustments for equity broking services. For non-DVP segment transactions, the tribunal applied CUP method comparing weighted average commission rates between associated enterprises and third-party FII clients, determining ALP brokerage rate at 0.41% after adjusting for sales/marketing functions. Port fee charges were accepted at cost plus 25% markup as per agreement rather than CIT(A)'s 15% markup. Administrative support services required no adjustment as assessee's 17.2% margin exceeded arm's length price of 13.67%. Program trades adjustment was rejected as these were third-party independent transactions. Section 14A disallowance was limited to suo-moto amount offered by assessee since Rule 8D wasn't applicable for AY 2002-03 and sufficient interest-free funds existed. Case-Laws Income Tax Mon, 10 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755054