https://www.taxtmi.com/caselaws?id=768412 ITAT Delhi upheld TPO's rejection of assessee's TP study, finding no infirmity in determining assessee as tested party rather than foreign AE service providers. Tribunal confirmed use of indigenous comparables over foreign ones and adoption of CUP method instead of TNMM for benchmarking. However, ITAT held TPO unjustified in setting ALP at NIL without proper examination of evidence. Tribunal directed TPO to analyze all submitted evidence and determine arm's length margin through applicable transfer pricing mechanisms before making adjustments. Kotak deemed suitable comparable for specific similar services comparison. en-us Wed, 02 Apr 2025 00:00:00 +0530 Mon, 07 Apr 2025 08:32:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768412 ITAT Delhi upheld TPO's rejection of assessee's TP study, finding no infirmity in determining assessee as tested party rather than foreign AE service providers. Tribunal confirmed use of indigenous comparables over foreign ones and adoption of CUP method instead of TNMM for benchmarking. However, ITAT held TPO unjustified in setting ALP at NIL without proper examination of evidence. Tribunal directed TPO to analyze all submitted evidence and determine arm's length margin through applicable transfer pricing mechanisms before making adjustments. Kotak deemed suitable comparable for specific similar services comparison. Case-Laws Income Tax Wed, 02 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768412