TP Adjustment - Provision of Administrative and Agency Services...

TP Adjustment - Provision of Administrative and Agency Services - Determination of Arm's Length Price (ALP) - allocation of expenses relating to income streams between two segments - The appellant challenged the actions of the Assessing Officer (AO) and Transfer Pricing Officer (TPO) in determining the ALP and rejecting their TP analysis. The Appellate Tribunal found in favor of the appellant, concluding that the TPO's actions were beyond jurisdiction and based on incorrect facts. The Tribunal upheld the appellant's use of Transfer Pricing Methodology and segmentation of accounts, directing the AO to delete the adjustments made.