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Income Tax - Highlights / Catch Notes

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TP Adjustment - receipt of management services from AEs - It is ...


TPO's 'NIL' Assessment of Management Services from AEs Challenged; Case Remanded for Proper Benchmarking.

July 27, 2019

Case Laws     Income Tax     AT

TP Adjustment - receipt of management services from AEs - It is difficult to prove the services in terms of numbers but it can be seen only in ease of doing business in India and satisfaction of the farmers who are availing the services - TPO taken ALP is ‘NIL’ and analysed the management services on benefit test which is not a method in the TP study - TPO should bench mark this transaction separately - remanded

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