Upward TP adjustment on account of reimbursement of expenses - ...

TPO's Unwarranted Transfer Pricing Adjustment Disallows Legitimate Business Expense Reimbursement, Violating ALP Standards.

December 6, 2021

Case Laws     Income Tax     AT

Upward TP adjustment on account of reimbursement of expenses - The expenses in question were thus clearly for the purpose of the business of the assessee, and deserved to be allowed in full. The TPO should not have ventured into the job of the AO, but that technicality apart, even on merits, entire related expenses, which have been wrongly disallowed by making an ALP- something clearly contrary to the scheme of the Act, these expenses were fully admissible for deduction. - AT

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