https://www.taxtmi.com/caselaws?id=459394 ITAT Mumbai remitted transfer pricing adjustments back to AO/TPO for proper benchmarking using CUP method instead of TNMM for cost allocation services, directing comparison with similar MNC services. For web hosting charges, tribunal ordered benchmarking of 5% markup using TNMM method with available comparables. Share-based payment addition was deleted as tribunal found actual employee benefit expenses were incurred, not notional losses as claimed by DRP. The case involved multiple transfer pricing issues requiring proper methodology application and verification of supporting documentation. en-us Wed, 07 Feb 2024 00:00:00 +0530 Wed, 11 Dec 2024 18:57:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459394 ITAT Mumbai remitted transfer pricing adjustments back to AO/TPO for proper benchmarking using CUP method instead of TNMM for cost allocation services, directing comparison with similar MNC services. For web hosting charges, tribunal ordered benchmarking of 5% markup using TNMM method with available comparables. Share-based payment addition was deleted as tribunal found actual employee benefit expenses were incurred, not notional losses as claimed by DRP. The case involved multiple transfer pricing issues requiring proper methodology application and verification of supporting documentation. Case-Laws Income Tax Wed, 07 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459394