https://www.taxtmi.com/caselaws?id=780263 ITAT MUMBAI - AT set aside the transfer-pricing addition and directed the TPO to compute the ALP of intra-group services (IGS) using the corroborative benchmarking analysis furnished by the taxpayer (Indian tested party, TNMM, PLI = operating profit/sales) after verifying PLI computation. The Tribunal rejected Revenue's contention equating the TPO approach to "Other Method," found the taxpayer had satisfied need/purpose/rendition/benefit tests, and held that the DRP's direction to disallow the IGS deduction under s.37 could not be sustained. en-us Thu, 16 Oct 2025 00:00:00 +0530 Mon, 27 Oct 2025 09:17:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780263 ITAT MUMBAI - AT set aside the transfer-pricing addition and directed the TPO to compute the ALP of intra-group services (IGS) using the corroborative benchmarking analysis furnished by the taxpayer (Indian tested party, TNMM, PLI = operating profit/sales) after verifying PLI computation. The Tribunal rejected Revenue's contention equating the TPO approach to "Other Method," found the taxpayer had satisfied need/purpose/rendition/benefit tests, and held that the DRP's direction to disallow the IGS deduction under s.37 could not be sustained. Case-Laws Income Tax Thu, 16 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780263