High Court allows ASK Re's appeals on transfer pricing and disallowance u/s 14A.

The High Court ruled in favor of ASK Re Ltd., a Hong Kong-based company, regarding transfer pricing and disallowance under Section 14A. The company was recognized as an Associated Enterprise under Section 92A(2)(j). The Court accepted the Comparable Uncontrolled Price (CUP) method as the most appropriate, rejecting the Transactional Net Margin Method (TNMM) and related transfer pricing adjustments. The disallowance under Section 14A, connected with Rule 8D, was removed since the assessee did not earn exempt income, referencing the Era Infrastructure and Maxivision Eye Hospital cases. The appeals on both transfer pricing and Section 14A issues were allowed. .....

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