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The ITAT set aside the transfer pricing adjustment made on the non-binding investment advisory services, holding that the addition of a 22% markup on top of cost-plus reimbursement was unwarranted, as the assessee's margin exceeded that of comparable companies. The Tribunal directed the assessee to furnish extrapolated financial data for R Systems International Ltd. for appropriate comparability analysis concerning ITeS transactions. Regarding the GST refund addition raised via intimation under section 143(1), the ITAT declined to adjudicate as the issue was not part of the assessment proceedings and instructed the AO to expedite disposal of the pending rectification application under section 154. On interest under section 234A, the matter was remanded for verification of timely filing of return and levy of interest if applicable. Grounds challenging transfer pricing adjustments were allowed, while other grounds were permitted for statistical purposes.
The ITAT set aside the transfer pricing adjustment made on the non-binding investment advisory services, holding that the addition of a 22% markup on top of cost-plus reimbursement was unwarranted, as the assessee's margin exceeded that of comparable companies. The Tribunal directed the assessee to furnish extrapolated financial data for R Systems International Ltd. for appropriate comparability analysis concerning ITeS transactions. Regarding the GST refund addition raised via intimation under section 143(1), the ITAT declined to adjudicate as the issue was not part of the assessment proceedings and instructed the AO to expedite disposal of the pending rectification application under section 154. On interest under section 234A, the matter was remanded for verification of timely filing of return and levy of interest if applicable. Grounds challenging transfer pricing adjustments were allowed, while other grounds were permitted for statistical purposes.
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