Once TNMM Is Applied PO Cannot Benchmark Management Fees Separately or Assign Nil ALP

Logwin Air & Ocean India Private Limited Vs ACIT (ITAT Mumbai) The appeal concerns the final assessment order dated 29.10.2024 issued under sections 143(3), 144C(13) and 144B of the Income Tax Act for AY 2011-12, following directions of the DRP. The assessee, engaged in international freight forwarding and part of the Logwin Group, challenged a transfer pricing adjustment of ₹1,04,21,731 relating to Management Fees, as well as an unrelated corporate tax addition under section 41(1). The assessee’s international transactions included freight and handling receipts and payments benchmarke...