High Court Favors Hong Kong Firm on Transfer Pricing, Rejects Disallowance Without Exempt Income, Accepts CUP Method.

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....M/s. ASK Re Ltd., Hong Kong held as Associated Enterprise u/s 92A(2)(j). CUP method accepted as Most Appropriate Method, rejecting TNMM and TP adjustment. Disallowance u/s 14A read with Rule 8D deleted as no exempt income earned by assessee, relying on Era Infrastructure and Maxivision Eye Hospital cases. Assessee's appeals allowed on TP and 14A issues.....