https://www.taxtmi.com/caselaws?id=462936 The ITAT Ahmedabad upheld the CIT(A)'s decision rejecting the AO's action of disallowing the books of accounts and estimating income under section 44BBB(1), ruling in favor of the assessee. The Tribunal affirmed that transactions between the foreign head office and its Indian project office constitute international transactions subject to transfer pricing provisions. It held that the CUP method, not TNMM, is appropriate for determining the arm's length price, and applying CUP resulted in no transfer pricing adjustment. The Tribunal also remanded the issue of whether the AO referred the matter to the TPO for determination of ALP back to the AO for verification, allowing this issue for statistical purposes. Overall, the appeal succeeded on substantive grounds except for the procedural matter sent back for further inquiry. en-us Fri, 13 Apr 2018 00:00:00 +0530 Fri, 25 Jul 2025 18:57:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462936 The ITAT Ahmedabad upheld the CIT(A)'s decision rejecting the AO's action of disallowing the books of accounts and estimating income under section 44BBB(1), ruling in favor of the assessee. The Tribunal affirmed that transactions between the foreign head office and its Indian project office constitute international transactions subject to transfer pricing provisions. It held that the CUP method, not TNMM, is appropriate for determining the arm's length price, and applying CUP resulted in no transfer pricing adjustment. The Tribunal also remanded the issue of whether the AO referred the matter to the TPO for determination of ALP back to the AO for verification, allowing this issue for statistical purposes. Overall, the appeal succeeded on substantive grounds except for the procedural matter sent back for further inquiry. Case-Laws Income Tax Fri, 13 Apr 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462936