https://www.taxtmi.com/caselaws?id=781690 ITAT held that the TPO's replacement of valuation projections with actuals was unreasonable and upheld the buyer's earlier third-party valuation; related transfer-pricing additions were disallowed. Matters concerning support-service charges, R&D service comparables, and selection of the most appropriate method were remitted to the AO/TPO for fresh determination of ALP/MAM (RPM or TNMM) after proper FAR analysis, with directions to afford hearing and for the assessee to produce cost and allocation data, working capital adjustments and other evidence. The remitted grounds were allowed for statistical purposes. en-us Mon, 10 Nov 2025 00:00:00 +0530 Wed, 19 Nov 2025 08:52:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781690 ITAT held that the TPO's replacement of valuation projections with actuals was unreasonable and upheld the buyer's earlier third-party valuation; related transfer-pricing additions were disallowed. Matters concerning support-service charges, R&D service comparables, and selection of the most appropriate method were remitted to the AO/TPO for fresh determination of ALP/MAM (RPM or TNMM) after proper FAR analysis, with directions to afford hearing and for the assessee to produce cost and allocation data, working capital adjustments and other evidence. The remitted grounds were allowed for statistical purposes. Case-Laws Income Tax Mon, 10 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781690