Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
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.
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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