https://www.taxtmi.com/caselaws?id=764263 ITAT Chennai held that Hong Kong entity qualified as Associated Enterprise under Section 92A(2)(j) being controlled by relatives of assessee's controlling shareholder. Tribunal rejected TPO's application of TNMM method, ruling CUP as most appropriate method where comparable third-party prices were available, allowing assessee's appeal on transfer pricing adjustment. Regarding Section 14A disallowance, ITAT ruled no disallowance permissible without exempt income, citing Era Infrastructure and Maxivision Eye Hospital precedents, deciding in assessee's favor. en-us Wed, 18 Dec 2024 00:00:00 +0530 Tue, 07 Jan 2025 07:56:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764263 ITAT Chennai held that Hong Kong entity qualified as Associated Enterprise under Section 92A(2)(j) being controlled by relatives of assessee's controlling shareholder. Tribunal rejected TPO's application of TNMM method, ruling CUP as most appropriate method where comparable third-party prices were available, allowing assessee's appeal on transfer pricing adjustment. Regarding Section 14A disallowance, ITAT ruled no disallowance permissible without exempt income, citing Era Infrastructure and Maxivision Eye Hospital precedents, deciding in assessee's favor. Case-Laws Income Tax Wed, 18 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764263