https://www.taxtmi.com/caselaws?id=768933 ITAT Delhi upheld assessee's aggregation approach for determining arm's length price of international transactions including AMP expenditure. Court found that import of raw materials, sale of semi-finished goods, and AMP transactions were closely connected, emanating from common agreement and inextricably linked. TPO failed to substantiate rejection of transfer pricing study with adequate evidence or comparability tests. TNMM at entity level was appropriate method. TPO erred in segregating three disputed transactions for separate arm's length determination. Disallowances under sections 37 and 36(1)(va) were upheld, with delayed PF contribution issue settled against assessee by SC precedent. en-us Wed, 19 Mar 2025 00:00:00 +0530 Wed, 16 Apr 2025 08:38:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768933 ITAT Delhi upheld assessee's aggregation approach for determining arm's length price of international transactions including AMP expenditure. Court found that import of raw materials, sale of semi-finished goods, and AMP transactions were closely connected, emanating from common agreement and inextricably linked. TPO failed to substantiate rejection of transfer pricing study with adequate evidence or comparability tests. TNMM at entity level was appropriate method. TPO erred in segregating three disputed transactions for separate arm's length determination. Disallowances under sections 37 and 36(1)(va) were upheld, with delayed PF contribution issue settled against assessee by SC precedent. Case-Laws Income Tax Wed, 19 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768933