https://www.taxtmi.com/caselaws?id=779678 ITAT MUMBAI held that the transfer pricing adjustment of INR 10,47,30,105 made by the TPO/AO lacked merit and directed its deletion, allowing grounds 4-10 of the appeal. The tribunal found the assessee's back-to-back bareboat charter arrangement with the associated enterprise produced an arm's length outcome; even after imputing a 2.5% commission the assessee's remuneration remained below comparables. The tribunal applied the benchmarking accepted in the earlier year and saw no change in facts. The AO was directed to compute interest under s.234C based on returned income. en-us Mon, 06 Oct 2025 00:00:00 +0530 Fri, 10 Oct 2025 08:44:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779678 ITAT MUMBAI held that the transfer pricing adjustment of INR 10,47,30,105 made by the TPO/AO lacked merit and directed its deletion, allowing grounds 4-10 of the appeal. The tribunal found the assessee's back-to-back bareboat charter arrangement with the associated enterprise produced an arm's length outcome; even after imputing a 2.5% commission the assessee's remuneration remained below comparables. The tribunal applied the benchmarking accepted in the earlier year and saw no change in facts. The AO was directed to compute interest under s.234C based on returned income. Case-Laws Income Tax Mon, 06 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779678