https://www.taxtmi.com/caselaws?id=362569 Transfer pricing benchmarking of group IT services was remitted for fresh enquiry because the factual questions on technical services and the DTAA "make available" clause had not been examined by the lower authorities. The disallowance under Section 40(a)(ia) was also sent back for reconsideration, and the High Court left open whether ALP/transfer pricing adjustments and Section 40(a)(ia) can operate concurrently until the Assessing Officer makes fresh findings. Carry forward loss for the relevant year was directed to be verified and appropriately adjusted on remand. en-us Tue, 19 Jun 2018 00:00:00 +0530 Thu, 28 Jun 2018 10:42:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=362569 Transfer pricing benchmarking of group IT services was remitted for fresh enquiry because the factual questions on technical services and the DTAA "make available" clause had not been examined by the lower authorities. The disallowance under Section 40(a)(ia) was also sent back for reconsideration, and the High Court left open whether ALP/transfer pricing adjustments and Section 40(a)(ia) can operate concurrently until the Assessing Officer makes fresh findings. Carry forward loss for the relevant year was directed to be verified and appropriately adjusted on remand. Case-Laws Income Tax Tue, 19 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=362569