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    <title>2025 (9) TMI 86 - ITAT CHENNAI</title>
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    <description>ITAT held the TPO erred in rejecting the assessee&#039;s internal CUP for sale of readymade garments, finding the AE acted as a pass-through with back-to-back invoicing and full disclosure; internal CUP (and alternatively internal TNMM) were appropriate and transactions were at arm&#039;s length, so the entire TP adjustment was deleted. The Tribunal also directed deletion of the s.14A disallowance because no exempt income arose in the year. Appeal of the assessee was allowed.</description>
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      <title>2025 (9) TMI 86 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=777597</link>
      <description>ITAT held the TPO erred in rejecting the assessee&#039;s internal CUP for sale of readymade garments, finding the AE acted as a pass-through with back-to-back invoicing and full disclosure; internal CUP (and alternatively internal TNMM) were appropriate and transactions were at arm&#039;s length, so the entire TP adjustment was deleted. The Tribunal also directed deletion of the s.14A disallowance because no exempt income arose in the year. Appeal of the assessee was allowed.</description>
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