https://www.taxtmi.com/caselaws?id=461501 ITAT PUNE ruled in favor of the assessee regarding transfer pricing adjustment for intra-group services. The assessee had applied TNMM method aggregating all transactions including raw material purchases and intra-group services, determining arm's length price at nil. TPO applied CUP method making upward adjustments for Marketing and Administrative Services segments. Following precedent from assessee's own case for AY 2009-10, ITAT reversed the lower authorities' orders, directing application of TNMM method for aggregate benchmarking of transactions. No adjustment was warranted for intra-group services payments. Appeal allowed. en-us Mon, 24 Jun 2019 00:00:00 +0530 Wed, 09 Apr 2025 18:59:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461501 ITAT PUNE ruled in favor of the assessee regarding transfer pricing adjustment for intra-group services. The assessee had applied TNMM method aggregating all transactions including raw material purchases and intra-group services, determining arm's length price at nil. TPO applied CUP method making upward adjustments for Marketing and Administrative Services segments. Following precedent from assessee's own case for AY 2009-10, ITAT reversed the lower authorities' orders, directing application of TNMM method for aggregate benchmarking of transactions. No adjustment was warranted for intra-group services payments. Appeal allowed. Case-Laws Income Tax Mon, 24 Jun 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461501