https://www.taxtmi.com/caselaws?id=771120 The ITAT Chennai allowed the appellant's appeal on three grounds. First, regarding TP adjustment for administrative support services, the Tribunal directed the AO to accept the assessee's benchmarking methodology based on comparable companies providing administrative support services, noting no adjustments were made in previous/subsequent years and employees were operational level. Second, for royalty payments to AEs, the Tribunal found the TPO incorrectly used prior year agreed prices as CUP method without identifying comparable uncontrolled transactions, directing acceptance of FTS payment at arm's length. Third, the disallowance of provision for expected contract losses under Section 37 was deleted, following precedent that such provisions constitute ascertained liabilities. en-us Fri, 02 May 2025 00:00:00 +0530 Mon, 19 May 2025 15:15:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771120 The ITAT Chennai allowed the appellant's appeal on three grounds. First, regarding TP adjustment for administrative support services, the Tribunal directed the AO to accept the assessee's benchmarking methodology based on comparable companies providing administrative support services, noting no adjustments were made in previous/subsequent years and employees were operational level. Second, for royalty payments to AEs, the Tribunal found the TPO incorrectly used prior year agreed prices as CUP method without identifying comparable uncontrolled transactions, directing acceptance of FTS payment at arm's length. Third, the disallowance of provision for expected contract losses under Section 37 was deleted, following precedent that such provisions constitute ascertained liabilities. Case-Laws Income Tax Fri, 02 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771120