https://www.taxtmi.com/caselaws?id=464692 ITAT PUNE - AT held that the tested-party selection excluding Chinese comparables was unsound and approved the authorities' rejection of the foreign affiliate in China as tested party. The Tribunal found RHQ services were actually availed and TPO's Nil ALP incorrect, directed benchmarking to be redetermined by AO/TPO using the assessee as tested party and remitted the matter for fresh ALP determination with opportunity of hearing. Orders on global software charges were set aside and remitted for redetermination. The assessee's segmentation and use of "any other method" for imports were rejected; benchmarking was flawed. TP addition must be confined to transactions with AEs under manufacturing activity, not at entity level. en-us Wed, 04 Aug 2021 00:00:00 +0530 Mon, 10 Nov 2025 15:49:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464692 ITAT PUNE - AT held that the tested-party selection excluding Chinese comparables was unsound and approved the authorities' rejection of the foreign affiliate in China as tested party. The Tribunal found RHQ services were actually availed and TPO's Nil ALP incorrect, directed benchmarking to be redetermined by AO/TPO using the assessee as tested party and remitted the matter for fresh ALP determination with opportunity of hearing. Orders on global software charges were set aside and remitted for redetermination. The assessee's segmentation and use of "any other method" for imports were rejected; benchmarking was flawed. TP addition must be confined to transactions with AEs under manufacturing activity, not at entity level. Case-Laws Income Tax Wed, 04 Aug 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464692