Transfer pricing adjustments remanded for fresh adjudication on intra-group services, benchmarking method, comparables, and risk adjustment.

Transfer pricing adjustments concerning intra-group services, the sensor assembling segment, and business support services were remitted for fresh adjudication because the existing record did not show a final and satisfactory examination of the disputed issues. The assessee's request for consideration of additional evidence on intra-group services, its challenge to the benchmarking method used for the sensor assembling segment, and its objections to filters, comparables, and risk adjustment for business support services were all found to require reconsideration. The matter was sent back to the Assessing Officer/Transfer Pricing Officer for fresh decision after granting an opportunity of hearing.

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Issues: Whether the transfer pricing adjustments relating to intra-group services, the sensor assembling segment, and business support services required to be set aside and remanded for fresh adjudication.

Analysis: The assessee sought consideration of additional evidence on the intra-group services issue and contended that the sensor assembling segment had been benchmarked on an incorrect method, while the business support services adjustment was challenged on the basis of disputed filters, comparables, and risk adjustment. The material on record showed that the Departmental Authorities had not finally and satisfactorily adjudicated these controversies on the existing record and that a fresh examination by the Transfer Pricing Officer was warranted. The grounds relating to the transfer pricing adjustments were therefore treated as requiring reconsideration in accordance with law after granting opportunity of hearing.

Conclusion: The transfer pricing issues were remitted to the Assessing Officer/Transfer Pricing Officer for fresh adjudication, and the assessee succeeded to that extent.

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