TP adjustment - Corporate/Management services fee - TPO cannot ...
TPO Cannot Reject Corporate Fees Based on Benefit; Must Focus on Arm's Length Price Assessment for Transactions.
April 27, 2019
Case Laws Income Tax AT
TP adjustment - Corporate/Management services fee - TPO cannot reject the allowability of expenses simply on the ground that no benefit was derived - It is for the assessee to decide the way in which it has to carry on its business - Once it is proved that the services were availed, then TPO jurisdiction gets restricted to determining the ALP of the transaction.
View Source