The ITAT held that the assessee's 5% markup charged for ...
IT Tribunal upholds 5% markup on intra-group services as arm's length based on TNMM analysis.
December 4, 2024
Case Laws Income Tax AT
The ITAT held that the assessee's 5% markup charged for intra-group services was at arm's length based on benchmarking analysis using the Transactional Net Margin Method (TNMM). It ruled that tax authorities cannot question commercial decisions or quantum of fees, but can only examine if services were actually rendered and transactions were genuine. Relying on judicial precedents, the ITAT directed the TPO to delete the impugned transfer pricing adjustment.
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