https://www.taxtmi.com/caselaws?id=327296 Transfer pricing adjustments for technical fees and group IT service charges paid to foreign associated enterprises require a fresh factual and benchmarking examination of the services actually received and their arm's length value; the earlier nil valuation was set aside and the matter remanded. Disallowance for non-deduction of tax at source on IT reimbursement also required scrutiny of the payment's nature and the applicable treaty position, including the make-available test, so the disallowance was remanded. The claim for correct carry forward loss was restored for verification from the assessment records, with relief to follow if admissible. en-us Thu, 31 Mar 2016 00:00:00 +0530 Fri, 06 May 2016 10:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=327296 Transfer pricing adjustments for technical fees and group IT service charges paid to foreign associated enterprises require a fresh factual and benchmarking examination of the services actually received and their arm's length value; the earlier nil valuation was set aside and the matter remanded. Disallowance for non-deduction of tax at source on IT reimbursement also required scrutiny of the payment's nature and the applicable treaty position, including the make-available test, so the disallowance was remanded. The claim for correct carry forward loss was restored for verification from the assessment records, with relief to follow if admissible. Case-Laws Income Tax Thu, 31 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=327296