https://www.taxtmi.com/caselaws?id=776116 The ITAT Mumbai allowed the TP adjustment challenge related to non-binding investment advisory services, holding there was no basis for adding a 22% markup since the assessee was already reimbursed on a cost-plus 22% basis and the comparable margin was only 7.93%. Regarding the ITeS transaction, the tribunal directed the assessee to provide extrapolated data of a comparable company for the relevant FY for TPO's examination. The tribunal declined to decide on the GST refund addition as it was not part of the scrutiny assessment and directed the AO to expedite the pending rectification application. On interest under section 234A, the AO was directed to verify the timeliness of return filing and levy interest if applicable. Grounds 1, 3, 4, and 5 were allowed for statistical purposes or directed for further verification. en-us Fri, 01 Aug 2025 00:00:00 +0530 Mon, 04 May 2026 14:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776116 The ITAT Mumbai allowed the TP adjustment challenge related to non-binding investment advisory services, holding there was no basis for adding a 22% markup since the assessee was already reimbursed on a cost-plus 22% basis and the comparable margin was only 7.93%. Regarding the ITeS transaction, the tribunal directed the assessee to provide extrapolated data of a comparable company for the relevant FY for TPO's examination. The tribunal declined to decide on the GST refund addition as it was not part of the scrutiny assessment and directed the AO to expedite the pending rectification application. On interest under section 234A, the AO was directed to verify the timeliness of return filing and levy interest if applicable. Grounds 1, 3, 4, and 5 were allowed for statistical purposes or directed for further verification. Case-Laws Income Tax Fri, 01 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776116