https://www.taxtmi.com/caselaws?id=461865 ITAT Pune ruled in favor of the assessee on multiple issues. For transfer pricing, the tribunal held that TNMM method should be applied for benchmarking international transactions, rejecting TPO's preference for cost plus method, based on consistent application in earlier years. Regarding sales tax discount, the tribunal sustained relief granted by CIT(A), following HC precedent that pre-payment discounts don't constitute cessation of liability under section 41(1). IT services disallowance was remitted to AO for verification. Section 14A disallowance was rejected as AO failed to record satisfaction before invoking the provision. en-us Wed, 09 Jan 2019 00:00:00 +0530 Sat, 03 May 2025 12:29:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461865 ITAT Pune ruled in favor of the assessee on multiple issues. For transfer pricing, the tribunal held that TNMM method should be applied for benchmarking international transactions, rejecting TPO's preference for cost plus method, based on consistent application in earlier years. Regarding sales tax discount, the tribunal sustained relief granted by CIT(A), following HC precedent that pre-payment discounts don't constitute cessation of liability under section 41(1). IT services disallowance was remitted to AO for verification. Section 14A disallowance was rejected as AO failed to record satisfaction before invoking the provision. Case-Laws Income Tax Wed, 09 Jan 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461865