https://www.taxtmi.com/caselaws?id=464350 ITAT Mumbai directed the TPO to re-determine ALP confined to the assessee's international transactions (not entire turnover); if the revised ALP falls within the safe-harbour ±5% no transfer-pricing adjustment is to be made. The Tribunal rejected adverse inferences about the assessee's cost-allocation methodology for lack of record of any opportunity given to justify it and accepted the allocation supported by a CA certificate (ground allowed). The claim for deduction of written-off debts was remitted to the AO for verification whether those amounts were earlier offered as income; any portion so verified shall be allowed (ground allowed for statistical purposes). en-us Wed, 30 Jan 2019 00:00:00 +0530 Fri, 24 Oct 2025 15:14:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464350 ITAT Mumbai directed the TPO to re-determine ALP confined to the assessee's international transactions (not entire turnover); if the revised ALP falls within the safe-harbour ±5% no transfer-pricing adjustment is to be made. The Tribunal rejected adverse inferences about the assessee's cost-allocation methodology for lack of record of any opportunity given to justify it and accepted the allocation supported by a CA certificate (ground allowed). The claim for deduction of written-off debts was remitted to the AO for verification whether those amounts were earlier offered as income; any portion so verified shall be allowed (ground allowed for statistical purposes). Case-Laws Income Tax Wed, 30 Jan 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464350