Transfer Price of Goods Sold via AE Allowed Based on ‘Other Method’ Instead of CUP

Rallis India Ltd. Vs ACIT (ITAT Mumbai)

Transfer Price/ALP of goods sold through AE to third party was allowed to be determined basis ‘Other method’ instead of CUP used by TPO/AO

Recently the Mumbai ITAT in the case of Rallis India Ltd. v. ACIT Mumbai (ITAT Order dated 13-12-2024), granted big relief to the Tata Group entity, Rallis India Ltd. The tribunal dealt with the issues of Transfer Pricing (TP) adjustments, disallowance of expenses under Section 14A, denial of deductions under Section 35(2AB), MAT credit mismatch, and interest levies.

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