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Transfer-pricing adjustments for the project business segment...

Transfer-pricing adjustments for project business and intra-group services were remanded for fresh consideration under DRP directions.

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Income Tax July 20, 2026 Case Laws AT
Transfer-pricing adjustments for the project business segment required fresh consideration in line with the Dispute Resolution Panel's directions, without adjudication of their merits. The ITAT restored this issue to the Transfer Pricing Officer for a lawful fresh determination after hearing the assessee. The arm's length price of intra-group services was also remanded because the Transfer Pricing Officer had accepted that price in a subsequent assessment year; the merits were not decided. The Transfer Pricing Officer must reconsider the issue after providing an opportunity of hearing. The appeals for the relevant assessment years were allowed for statistical purposes.

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Acts Income Tax