https://www.taxtmi.com/caselaws?id=776346 The ITAT Chennai held that transfer pricing provisions do not apply to an assessee taxed under the Tonnage Tax Scheme per section 115VP, as income computation under this scheme is based solely on ship tonnage and not on arm's length pricing. The upward adjustments made by the TPO and confirmed by the AO regarding charter hire charges and sale value of ships were deleted, being untenable in law. The tribunal also rejected the assessee's contention that disallowances made under section 143(1) could be challenged in the appeal arising from the assessment order under section 143(3). Consequently, the appeal was partly allowed, affirming that transfer pricing provisions are inapplicable to core activities of tonnage tax companies and disallowances under section 143(1) are not adjudicable in the present appeal. en-us Wed, 30 Jul 2025 00:00:00 +0530 Fri, 08 Aug 2025 05:20:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776346 The ITAT Chennai held that transfer pricing provisions do not apply to an assessee taxed under the Tonnage Tax Scheme per section 115VP, as income computation under this scheme is based solely on ship tonnage and not on arm's length pricing. The upward adjustments made by the TPO and confirmed by the AO regarding charter hire charges and sale value of ships were deleted, being untenable in law. The tribunal also rejected the assessee's contention that disallowances made under section 143(1) could be challenged in the appeal arising from the assessment order under section 143(3). Consequently, the appeal was partly allowed, affirming that transfer pricing provisions are inapplicable to core activities of tonnage tax companies and disallowances under section 143(1) are not adjudicable in the present appeal. Case-Laws Income Tax Wed, 30 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776346