TPO adjustment towards technical know-how fees after accepting entity level margins is unsustainable

Tata Power Solar Systems Limited Vs ACIT (ITAT Bangalore) ITAT Bangalore held that the adjustment made by the TPO towards technical know-how fees despite accepting the entity level margins is liable to be deleted. Facts- During the year under consideration, the assessee entered into various international transactions with its Associated Enterprises (AEs) which inter alia included payment towards technical know-how amounting to Rs.9,07,39,440. During the course of assessment, the TPO upon considering the benchmarking analysis of the assessee, accepted the same for all international transactions...