https://www.taxtmi.com/caselaws?id=459490 The HC upheld ITAT's decision annulling TP adjustments made by TPO and DRP. ITAT found that while TPO and DRP accepted TNMM as the most appropriate method for ALP determination, they erroneously made additions and exceeded their mandate by re-evaluating raw material costs. TPO improperly compared controlled transactions with other controlled transactions instead of uncontrolled transactions as required under Section 92F(ii). ITAT correctly determined that TPO's directions violated statutory requirements for ALP computation between unrelated parties in uncontrolled conditions. HC found no substantial question of law, confirming ITAT's factual findings and legal interpretation. en-us Mon, 19 Feb 2024 00:00:00 +0530 Mon, 16 Dec 2024 18:31:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459490 The HC upheld ITAT's decision annulling TP adjustments made by TPO and DRP. ITAT found that while TPO and DRP accepted TNMM as the most appropriate method for ALP determination, they erroneously made additions and exceeded their mandate by re-evaluating raw material costs. TPO improperly compared controlled transactions with other controlled transactions instead of uncontrolled transactions as required under Section 92F(ii). ITAT correctly determined that TPO's directions violated statutory requirements for ALP computation between unrelated parties in uncontrolled conditions. HC found no substantial question of law, confirming ITAT's factual findings and legal interpretation. Case-Laws Income Tax Mon, 19 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459490