Taxpayer Wins Challenge Against Transfer Pricing Officer's Arbitrary Rejection of Intra-Group Service Pricing Documentation Under Section 92C(3)

HC held that the Transfer Pricing Officer (TPO) improperly rejected the assessee's transfer pricing study for intra-group services. The ITAT's decision to remand the matter was upheld, requiring the TPO to re-examine the transfer pricing analysis and verify whether conditions under Section 92C(3) are satisfied before making any adjustment. The fundamental premise of the TPO that no services were received was rejected, necessitating a comprehensive reassessment of the intra-group service transaction's arm's length pricing. .....

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