https://www.taxtmi.com/caselaws?id=59726 ITAT held that the assessee had substantially complied with transfer-pricing documentation requirements and minor record deficiencies were not fatal; however the assessee's use of TNMM was rejected as it impermissibly used overall operating margins, attracting s.92C(3). Revenue's reliance on external CUP failed to prove it was the most appropriate method, so TP additions were not sustained. Ad hoc disallowances of sales promotion gifts were deleted. Interest income was held business income for tax purposes (with 90% exclusion under s.80HHC) and inclusion of sales-tax/excise in turnover for s.80HHC relief was denied; appeals allowed in part. en-us Fri, 06 Feb 2009 00:00:00 +0530 Mon, 17 Nov 2025 17:15:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59726 ITAT held that the assessee had substantially complied with transfer-pricing documentation requirements and minor record deficiencies were not fatal; however the assessee's use of TNMM was rejected as it impermissibly used overall operating margins, attracting s.92C(3). Revenue's reliance on external CUP failed to prove it was the most appropriate method, so TP additions were not sustained. Ad hoc disallowances of sales promotion gifts were deleted. Interest income was held business income for tax purposes (with 90% exclusion under s.80HHC) and inclusion of sales-tax/excise in turnover for s.80HHC relief was denied; appeals allowed in part. Case-Laws Income Tax Fri, 06 Feb 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59726