ITAT adjudicated transfer pricing dispute regarding service ...

Transfer Pricing Dispute: Insufficient Evidence Leads to Remand for Comprehensive Reassessment of Intercompany Service Charges

May 24, 2025

Case Laws Income Tax AT

ITAT adjudicated transfer pricing dispute regarding service charges paid to associated enterprises (AEs). The tribunal found insufficient documentary evidence proving the exact nature and commensurate value of marketing/sales support services rendered. While acknowledging potential business support requirements, ITAT determined the appellant failed to substantiate service specifics. Consequently, the tribunal set aside the original assessment order and remanded the matter to Assessing Officer/Transfer Pricing Officer for comprehensive re-examination, directing a detailed evaluation of evidential records. The appellant's appeal was allowed for statistical purposes, mandating a fresh assessment with opportunity to provide additional substantiating documentation regarding inter-company service transactions.

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ITAT adjudicated transfer pricing dispute regarding service ...

Transfer Pricing Dispute: Insufficient Evidence Leads to Remand for Comprehensive Reassessment of Intercompany Service Charges

May 24, 2025

Case Laws Income Tax AT

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