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

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. .....

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