https://www.taxtmi.com/caselaws?id=461617 The ITAT Hyderabad ruled in favor of the assessee on transfer pricing matters, holding that authorities cannot disallow expenditure for services rendered by associated enterprises when actual rendition and utility are undisputed. The Tribunal applied the principle that expenditure incurred wholly and exclusively for business purposes is allowable, regardless of necessity or profitability. Following precedent from Knorr Bremse India case, ITAT held TNMM was the most appropriate method over CUP when comparable independent transactions were unavailable. The Tribunal also applied the Rule of Consistency, rejecting revenue's varying positions across years for identical circumstances. en-us Tue, 18 Jul 2023 00:00:00 +0530 Wed, 16 Apr 2025 20:54:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461617 The ITAT Hyderabad ruled in favor of the assessee on transfer pricing matters, holding that authorities cannot disallow expenditure for services rendered by associated enterprises when actual rendition and utility are undisputed. The Tribunal applied the principle that expenditure incurred wholly and exclusively for business purposes is allowable, regardless of necessity or profitability. Following precedent from Knorr Bremse India case, ITAT held TNMM was the most appropriate method over CUP when comparable independent transactions were unavailable. The Tribunal also applied the Rule of Consistency, rejecting revenue's varying positions across years for identical circumstances. Case-Laws Income Tax Tue, 18 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461617