2024 (3) TMI 1443

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..... Adv. For the Respondent : Mr. Ajay Vohra, Sr. Adv. With Mr. Samarth Chaudhari, Adv. ORDER 1. We take note of the contention of Mr. Bhatia, learned counsel appearing for the appellants, who draws our attention to the following extracts from the order of the Transfer Pricing Officer ["TPO"]: " Moreover, it is seen from the details contained in the transfer This is a digitally signed order. .....

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..... ently ascertaining the value of the goods/ services intended to be availed, in the market and that too at the best negotiated prices. No such effort has been demonstrated to be made at the end of the assessee, which weighs heavily against the normal practises of business prudence." 2. It is in the aforesaid backdrop that Mr. Bhatia contends that benchmarking in respect of Inter Group Services wa .....

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..... nd on facts, in concluding that the Appellant has derived no benefits from the intra-group services availed from the associated enterprises and arbitrarily determining the arm's length price of said international transaction as Nil as against the actual transaction value of Rs. 5,32,51,014/-." 4. However, in order to cut short the controversy which stands raised, we request the respondent to pla .....

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