https://www.taxtmi.com/caselaws?id=778995 ITAT held that the taxpayer satisfactorily proved receipt of bundled IT, PTSE and centralized services from associated enterprises through agreements, emails, invoices and financials of the AEs, and rejected the transfer-pricing adjustment. The Tribunal found the TPO/DRP failed to engage with the submitted evidence and relied on conjecture; CUP was inapplicable absent comparable uncontrolled transactions identified by the authorities. Finding no basis for an adhoc markup, ITAT set ALP at nil and disallowed the TP upward adjustment. en-us Mon, 20 Jan 2025 00:00:00 +0530 Thu, 25 Sep 2025 17:34:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778995 ITAT held that the taxpayer satisfactorily proved receipt of bundled IT, PTSE and centralized services from associated enterprises through agreements, emails, invoices and financials of the AEs, and rejected the transfer-pricing adjustment. The Tribunal found the TPO/DRP failed to engage with the submitted evidence and relied on conjecture; CUP was inapplicable absent comparable uncontrolled transactions identified by the authorities. Finding no basis for an adhoc markup, ITAT set ALP at nil and disallowed the TP upward adjustment. Case-Laws Income Tax Mon, 20 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778995