Overseas and Domestic Comparables Can Be Used Under CUP: ITAT Mumbai

Advertisement Morgan Stanley India Company Pvt. Ltd. Vs ITO (ITAT Mumbai) The Income Tax Appellate Tribunal (ITAT), Mumbai, disposed of the cross appeals filed by the assessee and the Revenue for Assessment Year 2004-05. In the assessee’s appeal, the Tribunal recorded that the grounds relating to the applicability of transfer pricing regulations, applicability of the Transactional Net Margin Method (TNMM), brokerage rates charged between MS Mauritius and third-party brokers, and the contention that the joint venture structure ensured arm’s length pricing were not pressed and wer...