Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
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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