https://www.taxtmi.com/caselaws?id=465113 ITAT Delhi upheld application of TNMM by AO/TPO for determining arm's length price of specified domestic transactions, holding that comparison of the eligible unit's margin with margins of comparable companies selected by the assessee was proper and that margins of other eligible units (being related party transactions) could not be used as comparables. It rejected the assessee's plea for invoice-based verification, as CUP was not the adopted method. The Tribunal held AO/TPO unjustified in making adjustment to allocation of common/head office expenses and directed exclusion of such expenses from the quantum of specified domestic transactions. On allocation of finance cost, the matter was remanded to AO/TPO to identify non-unit-specific interest and reallocate it among units, granting the assessee opportunity of hearing. en-us Tue, 23 Apr 2019 00:00:00 +0530 Sat, 06 Dec 2025 18:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465113 ITAT Delhi upheld application of TNMM by AO/TPO for determining arm's length price of specified domestic transactions, holding that comparison of the eligible unit's margin with margins of comparable companies selected by the assessee was proper and that margins of other eligible units (being related party transactions) could not be used as comparables. It rejected the assessee's plea for invoice-based verification, as CUP was not the adopted method. The Tribunal held AO/TPO unjustified in making adjustment to allocation of common/head office expenses and directed exclusion of such expenses from the quantum of specified domestic transactions. On allocation of finance cost, the matter was remanded to AO/TPO to identify non-unit-specific interest and reallocate it among units, granting the assessee opportunity of hearing. Case-Laws Income Tax Tue, 23 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465113