https://www.taxtmi.com/caselaws?id=773888 ITAT Ahmedabad ruled in favor of the assessee regarding transfer pricing adjustment. The tribunal held that CUP method was inapplicable due to fundamental differences not reasonably adjustable, and TNMM was the most appropriate method under Rule 10C(2) read with Rule 10B(1)(e). The assessee company obtained license from international breeder to multiply seeds and produce specialized potatoes, making it a complex entity, while the related party was merely a trader without intangibles, qualifying as the tested party. The tribunal accepted the assessee's benchmarking using reliable databases and found the transactions at arm's length, deleting the transfer pricing adjustment. Consequently, penalty proceedings under sections 270A and 271AA were rendered infructuous. The matter regarding MAT credit computation was remanded to assessing officer for verification. en-us Wed, 25 Jun 2025 00:00:00 +0530 Mon, 30 Jun 2025 08:43:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773888 ITAT Ahmedabad ruled in favor of the assessee regarding transfer pricing adjustment. The tribunal held that CUP method was inapplicable due to fundamental differences not reasonably adjustable, and TNMM was the most appropriate method under Rule 10C(2) read with Rule 10B(1)(e). The assessee company obtained license from international breeder to multiply seeds and produce specialized potatoes, making it a complex entity, while the related party was merely a trader without intangibles, qualifying as the tested party. The tribunal accepted the assessee's benchmarking using reliable databases and found the transactions at arm's length, deleting the transfer pricing adjustment. Consequently, penalty proceedings under sections 270A and 271AA were rendered infructuous. The matter regarding MAT credit computation was remanded to assessing officer for verification. Case-Laws Income Tax Wed, 25 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773888