Transfer Pricing Appeal: ITAT Accepts 8.70% Interest Rate on Masala Bonds, Orders TPO Review of Aggregation Method

ITAT partially allowed the appeal concerning transfer pricing matters. The Tribunal remanded the aggregation approach issue back to TPO for verification of inter-linked transactions with documentary evidence, rejecting automatic reliance on previous years' decisions due to substantial changes in service nature. On Masala Bonds, ITAT accepted assessee's position allowing interest rate of 8.70% p.a. instead of TPO's 7.53% benchmark. The Tribunal directed refund of excess DDT payment subject to verification. Regarding tax credits, AO was instructed to allow appropriate MAT and TCS credits after record verification. TNMM application was scrutinized against TPO's preference for CUP and OM methods, emphasizing the need for transaction-specific analysis rather than blanket application of previous years' approaches. .....

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