Income Tax - Highlights / Catch Notes

The ITAT Mumbai held that the Transfer Pricing Officer (TPO) ...

ITAT Mumbai upheld assessee's benchmarking analysis for TP adjustment, rejecting TPO's adhoc estimation. MAT credit entitlement to be verified. Disallowance u/s 14A r.w.r. 8D deleted as no claim for exempt dividend income.

Case Laws Income Tax

May 21, 2024

The ITAT Mumbai held that the Transfer Pricing Officer (TPO) unjustifiably rejected the benchmarking analysis done by the assessee for determining the Arm's Length Price (ALP) of services. The TPO's adhoc estimation lacked proper basis and reasoning, while the assessee's detailed analysis and need and benefit test were found to be satisfactory. The TPO's rejection of the benchmarking using the associated enterprise as a tested party was deemed incorrect, as the foreign associated enterprise was accepted as a tested party for benchmarking. The TPO's adhoc determination of TP adjustment was rejected, and the MAT credit entitlement issue was directed for further verification. The disallowance under section 14A r.w.r. 8D was deleted as the assessee did not claim dividend income as exempt.

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The ITAT Mumbai held that the Transfer Pricing Officer (TPO) ...

ITAT Mumbai upheld assessee's benchmarking analysis for TP adjustment, rejecting TPO's adhoc estimation. MAT credit entitlement to be verified. Disallowance u/s 14A r.w.r. 8D deleted as no claim for exempt dividend income.

Case Laws Income Tax

May 21, 2024

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