Improper Aggregation of International Transactions for Transfer Pricing Analysis Rejected Under Rule 10D

ITAT rejected the TPO's approach of aggregating all international transactions for transfer pricing analysis. The Tribunal found that the TPO improperly combined payment and receipt of intra-group services (IGS) using the same OP/OC or OP/OR benchmarking metrics, despite the assessee maintaining separate "Craft division" accounts. The TPO failed to provide adequate opportunity for the assessee to substantiate its cost allocation basis between divisions. The matter was remanded to the TPO to conduct separate benchmarking for services rendered and received using appropriate methods (TNMM or CUP) under Rule 10D. The appeal was decided in favor of the assessee for statistical purposes. .....

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