Bench: Shri Chandra Poojari & Smt Beena Pillai
Method ["TNMM"] and are tested by transfer pricing analysis and hence disallowance under section 40A(2) of the Act is bad in law. 4. The learned CIT(A) erred in disregarding the documentary evidences in the form of agreements, email correspondences and other supporting documents which proves the necessity, reasonability and the corresponding tangible benefits accruing from the service received