Decision upholds assessee's transfer pricing benchmarking for bareboat charter, deletes INR10,47,30,105 adjustment, directs s.234C interest

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....ITAT upheld the assessee's benchmarking and held the arm's-length outcome for the bareboat charter hire arrangement with the associated enterprise; the Tribunal found no merit in the TPO/AO's transfer-pricing adjustment of INR 10,47,30,105 and directed its deletion, allowing grounds 4-10 of the assessee's appeal. The Tribunal relied on the consistent facts and prior DRP acceptance in earlier year, noting comparability and that even after imputing a 2.5% commission the assessee's remuneration remained within comparable limits. The Tribunal further directed the jurisdictional AO to compute interest under s.234C of the Act in accordance with "returned income."....