https://www.taxtmi.com/caselaws?id=768557 The ITAT Pune-AT ruled in favor of the assessee regarding TP adjustment for cost sharing charges. The TPO claimed to use the CUP method but failed to identify any comparable uncontrolled transaction or price, merely referencing the method without proper application. The court held that no prescribed method was actually adopted for determining the Arm's Length Price. Following the precedent in CIT v. Johnson & Johnson Ltd., the tribunal ruled that TP adjustments without following prescribed methods are legally incorrect. Consequently, the addition made by the Assessing Officer/TPO/DRP was deleted, and the assessee's grounds were allowed. en-us Tue, 04 Mar 2025 00:00:00 +0530 Wed, 09 Apr 2025 07:42:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768557 The ITAT Pune-AT ruled in favor of the assessee regarding TP adjustment for cost sharing charges. The TPO claimed to use the CUP method but failed to identify any comparable uncontrolled transaction or price, merely referencing the method without proper application. The court held that no prescribed method was actually adopted for determining the Arm's Length Price. Following the precedent in CIT v. Johnson & Johnson Ltd., the tribunal ruled that TP adjustments without following prescribed methods are legally incorrect. Consequently, the addition made by the Assessing Officer/TPO/DRP was deleted, and the assessee's grounds were allowed. Case-Laws Income Tax Tue, 04 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768557