https://www.taxtmi.com/caselaws?id=767558 ITAT Delhi ruled in favor of the assessee on transfer pricing adjustment involving international transactions. The TPO incorrectly adopted an aggregated approach to benchmark all transactions using the same operating profit margin, combining both payment and receipt of services. The Tribunal found that TPO rejected the assessee's separate craft division submissions without proper consideration and failed to benchmark different types of services separately. The matter was remitted back to TPO to conduct fresh benchmarking using appropriate methods (TNMM or CUP) for each service category after providing adequate hearing opportunity to the assessee. en-us Wed, 19 Mar 2025 00:00:00 +0530 Fri, 21 Mar 2025 08:22:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767558 ITAT Delhi ruled in favor of the assessee on transfer pricing adjustment involving international transactions. The TPO incorrectly adopted an aggregated approach to benchmark all transactions using the same operating profit margin, combining both payment and receipt of services. The Tribunal found that TPO rejected the assessee's separate craft division submissions without proper consideration and failed to benchmark different types of services separately. The matter was remitted back to TPO to conduct fresh benchmarking using appropriate methods (TNMM or CUP) for each service category after providing adequate hearing opportunity to the assessee. Case-Laws Income Tax Wed, 19 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767558