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Income Tax - Highlights / Catch Notes

Home Highlights April 2023 Year 2023 This

TP Adjustment - Recovery of expenses represent expenses incurred ...


Transfer Pricing Officer's Decision on Bid Bond Expense Recovery with 10% Markup Overturned; ALP Set Above Nil.

April 6, 2023

Case Laws     Income Tax     AT

TP Adjustment - Recovery of expenses represent expenses incurred by the assessee company on behalf of AE towards Bid bond expenses. These expenses were also recovered by the assessee from its AE with markup of 10%. Hence, the reasoning given by us hereinabove for reimbursement of expenses would apply for this issue of recovery of expenses also. Hence, we dismiss the action of the ld. TPO in determining the ALP of this transaction at Nil - AT

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