https://www.taxtmi.com/caselaws?id=765410 ITAT Hyderabad ruled on transfer pricing adjustments involving aggregate transaction approach and TNMM benchmarking. The tribunal remanded the matter to TPO to verify documentary evidence establishing close inter-linking between transactions before allowing aggregate approach, noting substantial changes in service nature compared to previous years. However, ITAT allowed assessee's appeal regarding Masala Bond interest rate benchmarking at 8.70% per annum instead of TPO's 7.53%. The tribunal also directed AO to refund excess DDT payments and provide proper MAT/TCS credits after verification. Appeal partially allowed with remand on primary transfer pricing issue. en-us Mon, 30 Dec 2024 00:00:00 +0530 Fri, 31 Jan 2025 07:54:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765410 ITAT Hyderabad ruled on transfer pricing adjustments involving aggregate transaction approach and TNMM benchmarking. The tribunal remanded the matter to TPO to verify documentary evidence establishing close inter-linking between transactions before allowing aggregate approach, noting substantial changes in service nature compared to previous years. However, ITAT allowed assessee's appeal regarding Masala Bond interest rate benchmarking at 8.70% per annum instead of TPO's 7.53%. The tribunal also directed AO to refund excess DDT payments and provide proper MAT/TCS credits after verification. Appeal partially allowed with remand on primary transfer pricing issue. Case-Laws Income Tax Mon, 30 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765410