ITAT remanded the transfer pricing (TP) adjustment matter ...

Taxpayer Wins on Transfer Pricing Method and SEZ Service Deductions, Tribunal Orders Fresh Assessment and Deduction Restoration

April 16, 2025

Case Laws Income Tax AT

ITAT remanded the transfer pricing (TP) adjustment matter relating to support services payment to AO for fresh consideration, finding that TPO erroneously rejected the Transactional Net Margin Method (TNMM) as the Most Appropriate Method (MAM). Regarding Section 10AA deduction for Special Economic Zone (SEZ) services, the Tribunal held that services provided to foreign customers involving warehousing, logistics, and handling qualify under SEZ Act definitions. The Tribunal directed the AO to delete disallowances, noting prior assessments had accepted the deduction's eligibility, and finding the services met statutory requirements for claiming deduction under Section 10AA of the Income Tax Act.

View Source

← Previous Next →

ITAT remanded the transfer pricing (TP) adjustment matter ...

Taxpayer Wins on Transfer Pricing Method and SEZ Service Deductions, Tribunal Orders Fresh Assessment and Deduction Restoration

April 16, 2025

Case Laws Income Tax AT

You may also like:

ITAT ruled that the Transfer Pricing Officer (TPO) improperly determined Arm's Length Price (ALP) without following prescribed methods under Rule 10B. The TPO merely...

The Appellate Tribunal (ITAT) considered Transfer Pricing (TP) adjustments related to foreign exchange gains and engineering services. The assessee used Transactional...

The High Court upheld the order of the Income Tax Appellate Tribunal (ITAT) which had approved the Comparable Uncontrolled Price (CUP) method adopted by the assessee for...

Transfer Pricing Adjustment - arm's length price (ALP) of international transactions- MAM - “other method” - The Tribunal analyzed the transfer pricing methods applied...

Deduction u/s 80IA in respect of profits of captive power plants ('CPPs') - The tribunal, referring to the Comparable Uncontrolled Price (CUP) method and previous...

This is a summary of an Income Tax Appellate Tribunal (ITAT) order dealing with various transfer pricing and deduction issues. The key points are: Transfer pricing...

The Income Tax Appellate Tribunal held that the export commission paid by the assessee to foreign agents in Korea and Indonesia for sales, marketing, and customer...

The Tribunal meticulously analyzed each issue, heavily relying on precedent ITAT decisions and the specifics of the case presented. For the major contentious points,...

ITAT addressed transfer pricing adjustment regarding business support services between associated enterprises. TPO rejected assessee's TNMM method and entity-level...

ITAT adjudicated a transfer pricing dispute involving international transactions. The tribunal upheld the TPO's rejection of the assessee's transfer pricing study,...

ITAT adjudicated transfer pricing dispute involving manufacturing and service segments. Tribunal found substantial merit in assessee's contentions regarding arm's length...

Transfer Pricing (TP) adjustments - Transfer Pricing (TP) adjustments - debar of deduction u/s 10A on addition income assessed u/s 92CD as per the Proviso to 92C(4) -...

The Appellate Tribunal reviewed a case involving Transfer Pricing (TP) Adjustment for management service fee paid to Associated Enterprises. It was held that the...

The Principal Commissioner or Commissioner having jurisdiction over transfer pricing matters has been empowered, effective April 1, 2022, to invoke revisionary action...

Transfer pricing adjustments, selection of the most appropriate method (MAM), benchmarking approach (aggregation or segregation), factual rendering of services, arm's...

Quick Updates: