TP adjustment rejected as margin determined falls within tolerance limit of +/- 5%: ITAT Mumbai

ITO – 10(3)(4) Vs Excult Client Services I P Ltd. (ITAT Mumbai) ITAT Mumbai rejected the transfer pricing adjustment as margin which has been determined falls within the tolerance limit of +/- 5% as provided in proviso to Section 92CA of the Income Tax Act. Facts- The assessee is engaged in the business of providing range of back office support services. It is a captive service provider for its group entities. During the year, assessee had entered into international transactions with its AEs. Assessee has benchmarked the transaction for ITES and IT services by adopting TNMM as Most...