Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2022 (5) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2022 (5) TMI 1409 - ITAT DELHITP Adjustment - Engineering services and Administrative Support services - TPO has rejected the segmental approach adopted by the assessee for benchmarking its international transactions pertaining to provision of outbound engineering services (which is only 0.79% of the total turnover of the assessee) - HELD THAT:- As in the year of account the assessee availed the Engineering services and Administrative Support services from its AEs as per the service agreement dated 23.06.2006 entered into between the assessee and its AE for which the assessee incurred impugned expenditure. The expenditure has been incurred against invoices raised by the recipient AE which have also been examined during the course of transfer pricing proceedings. There is absolutely no doubt that the impugned expenditure has been incurred for the purposes of assessee’s business carried on by the assessee and that it was commercially expedient as well. The objections raised by the Hon’ble DRP have also been met by the assessee with cogent reasons given therefore. We, therefore, have no hesitation in holding that the impugned addition by way of transfer pricing adjustment is not called for. We direct the Ld. AO to delete the addition and modify the assessment. The assessee succeeds in its appeal.
|