https://www.taxtmi.com/caselaws?id=774533 ITAT Pune dismissed Revenue's appeal regarding transfer pricing adjustment on management fees paid to associated enterprise. TPO arbitrarily determined arm's length price as nil using "other method" under Rule 10AB without providing comparable uncontrolled transactions or proper justification. CIT(A) correctly deleted the addition, finding TPO's approach fundamentally flawed as it failed to comply with statutory requirements. Assessee adequately demonstrated receipt of commercial, operational, HR and financial support services through detailed documentation including service agreements, cost allocations, and email correspondences. Revenue failed to provide adverse material questioning service receipt. Court held TPO's role limited to determining arm's length price, not assessing business necessity of expenses. en-us Tue, 08 Jul 2025 00:00:00 +0530 Fri, 12 Jun 2026 14:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774533 ITAT Pune dismissed Revenue's appeal regarding transfer pricing adjustment on management fees paid to associated enterprise. TPO arbitrarily determined arm's length price as nil using "other method" under Rule 10AB without providing comparable uncontrolled transactions or proper justification. CIT(A) correctly deleted the addition, finding TPO's approach fundamentally flawed as it failed to comply with statutory requirements. Assessee adequately demonstrated receipt of commercial, operational, HR and financial support services through detailed documentation including service agreements, cost allocations, and email correspondences. Revenue failed to provide adverse material questioning service receipt. Court held TPO's role limited to determining arm's length price, not assessing business necessity of expenses. Case-Laws Income Tax Tue, 08 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774533