https://www.taxtmi.com/caselaws?id=780141 ITAT held that the taxpayer's use of TNMM with a 6.32% median from 13 comparables was acceptable and rejected the TPO/AO's denial of ALP on grounds of missing evidence of services by the AE, noting existence of a Master Services Agreement and continuous provision of onsite and 24/7 support to the US client. The TP adjustment was deleted as unjustified. The tribunal also directed the AO to verify the claimant's suo motu disallowance for delayed PF/ESI contributions and to delete any double disallowance if confirmed. en-us Wed, 24 Sep 2025 00:00:00 +0530 Fri, 24 Oct 2025 09:18:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780141 ITAT held that the taxpayer's use of TNMM with a 6.32% median from 13 comparables was acceptable and rejected the TPO/AO's denial of ALP on grounds of missing evidence of services by the AE, noting existence of a Master Services Agreement and continuous provision of onsite and 24/7 support to the US client. The TP adjustment was deleted as unjustified. The tribunal also directed the AO to verify the claimant's suo motu disallowance for delayed PF/ESI contributions and to delete any double disallowance if confirmed. Case-Laws Income Tax Wed, 24 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780141