https://www.taxtmi.com/caselaws?id=779776 ITAT (Chennai) allowed the appeal, holding the taxpayer reasonably quantified benefit from AE-provided Global Account Management (GAM) support and validly applied TNMM by aggregating GAM charges with core operations. The Tribunal found the 5% mark-up reasonable, noted absence of separate commission payments, and held substance over form prevents segregated benchmarking of GAM charges. TPO was incorrect to exclude GAM from the overall TNMM analysis. The AO's addition for downward adjustment of management fees was set aside and the impugned addition deleted in favor of the taxpayer. en-us Wed, 20 Aug 2025 00:00:00 +0530 Mon, 13 Oct 2025 08:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779776 ITAT (Chennai) allowed the appeal, holding the taxpayer reasonably quantified benefit from AE-provided Global Account Management (GAM) support and validly applied TNMM by aggregating GAM charges with core operations. The Tribunal found the 5% mark-up reasonable, noted absence of separate commission payments, and held substance over form prevents segregated benchmarking of GAM charges. TPO was incorrect to exclude GAM from the overall TNMM analysis. The AO's addition for downward adjustment of management fees was set aside and the impugned addition deleted in favor of the taxpayer. Case-Laws Income Tax Wed, 20 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779776