<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>Appeal partly allowed: transfer pricing CUP method remitted for fresh scrutiny, interest of Rs.17,57,358 allowed</title>
    <link>https://www.taxtmi.com/highlights?id=91854</link>
    <description>The ITAT partly allowed the appeal of the assessee. The Tribunal restored transfer-pricing issues (grounds 4-11) to the file of the Ld. CIT(A) for reconsideration, holding that the CUP method&#039;s functional applicability required fresh scrutiny and could not be rejected summarily in favour of TNMM. The disallowance for interest on working-capital (grounds 12-12.2) was deleted and interest of Rs.17,57,358 allowed, the AO having taken an inconsistent stance vis-Ã -vis TPO findings. The CIT(A)&#039;s direction to verify bad-debt admissibility was set aside. Miscellaneous expense disallowance (ground 14) was allowed; certain communication- and prior-period expense issues (grounds 15, 15.1 and 14-14.1) were remitted to the AO for verification.</description>
    <language>en-us</language>
    <pubDate>Sat, 23 Aug 2025 08:31:25 +0530</pubDate>
    <lastBuildDate>Sat, 23 Aug 2025 08:31:27 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=845431" rel="self" type="application/rss+xml"/>
    <item>
      <title>Appeal partly allowed: transfer pricing CUP method remitted for fresh scrutiny, interest of Rs.17,57,358 allowed</title>
      <link>https://www.taxtmi.com/highlights?id=91854</link>
      <description>The ITAT partly allowed the appeal of the assessee. The Tribunal restored transfer-pricing issues (grounds 4-11) to the file of the Ld. CIT(A) for reconsideration, holding that the CUP method&#039;s functional applicability required fresh scrutiny and could not be rejected summarily in favour of TNMM. The disallowance for interest on working-capital (grounds 12-12.2) was deleted and interest of Rs.17,57,358 allowed, the AO having taken an inconsistent stance vis-Ã -vis TPO findings. The CIT(A)&#039;s direction to verify bad-debt admissibility was set aside. Miscellaneous expense disallowance (ground 14) was allowed; certain communication- and prior-period expense issues (grounds 15, 15.1 and 14-14.1) were remitted to the AO for verification.</description>
      <category>Highlights</category>
      <law>Income Tax</law>
      <pubDate>Sat, 23 Aug 2025 08:31:25 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/highlights?id=91854</guid>
    </item>
  </channel>
</rss>