https://www.taxtmi.com/caselaws?id=773821 ITAT Mumbai set aside TPO's upward adjustment of management fees and R&D payments to associated enterprises. TPO had rejected assessee's documentation as inadequate without proper examination or computing adjustment per prescribed methods. Despite assessee filing additional evidence including agreements and correspondence before DRP, no remand report was obtained from TPO as directed. Following CIT vs Lever India Exports Limited precedent that TPO lacks jurisdiction over section 37 expenditure tests, ITAT restored matter to TPO for fresh computation, directing assessee to provide requisite details. Appeal allowed for statistical purposes. en-us Wed, 25 Jun 2025 00:00:00 +0530 Fri, 27 Jun 2025 12:44:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773821 ITAT Mumbai set aside TPO's upward adjustment of management fees and R&D payments to associated enterprises. TPO had rejected assessee's documentation as inadequate without proper examination or computing adjustment per prescribed methods. Despite assessee filing additional evidence including agreements and correspondence before DRP, no remand report was obtained from TPO as directed. Following CIT vs Lever India Exports Limited precedent that TPO lacks jurisdiction over section 37 expenditure tests, ITAT restored matter to TPO for fresh computation, directing assessee to provide requisite details. Appeal allowed for statistical purposes. Case-Laws Income Tax Wed, 25 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773821