TP Adjustment - ALP adjustment qua receipt of management ...
Income Tax
June 5, 2021
TP Adjustment - ALP adjustment qua receipt of management services - the assessee has already filed its detailed paper book in the nature of supportive evidence indicating receipt of management services in day to day functioning from its overseas Associated Enterprises. There is no rebuttal coming from Revenue’s side that all the said details lack genuineness which could be taken as the benchmark for arriving at nil ‘ALP’ thereof. We thus hold that the learned lower authorities action making impugned ALP adjustment is not sustainable.- AT
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