https://www.taxtmi.com/caselaws?id=462561 The ITAT Mumbai allowed the assessee's appeal regarding TP adjustment on management fees paid to its AE. The TPO rejected the assessee's TNMM method and TP study, arguing the assessee hadn't availed majority of services under the umbrella agreement. The Tribunal held that availing even some services from a composite agreement suffices to prove consideration paid to AEs. The TPO lacks authority to determine benefit derivation from intra-group services - this falls under AO's jurisdiction. The TPO's role is restricted to determining if transactions are at arm's length price. The TPO failed to justify rejecting TNMM method, and the Tribunal found the transaction at ALP. The TDS credit issue was remanded to AO for factual verification. en-us Mon, 04 Sep 2023 00:00:00 +0530 Tue, 01 Jul 2025 19:08:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462561 The ITAT Mumbai allowed the assessee's appeal regarding TP adjustment on management fees paid to its AE. The TPO rejected the assessee's TNMM method and TP study, arguing the assessee hadn't availed majority of services under the umbrella agreement. The Tribunal held that availing even some services from a composite agreement suffices to prove consideration paid to AEs. The TPO lacks authority to determine benefit derivation from intra-group services - this falls under AO's jurisdiction. The TPO's role is restricted to determining if transactions are at arm's length price. The TPO failed to justify rejecting TNMM method, and the Tribunal found the transaction at ALP. The TDS credit issue was remanded to AO for factual verification. Case-Laws Income Tax Mon, 04 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462561