https://www.taxtmi.com/caselaws?id=382294 The tribunal determined that the international transaction involving payment for management services was at Arm's Length Price (ALP), rejecting the Transfer Pricing Officer's contention of Nil ALP for stewardship activities. It was held that separate benchmarking was required for the transaction, distinct from other international transactions. The nature of services provided was deemed as management support services, not stewardship activities, supported by detailed documentation. The tribunal emphasized the necessity of applying prescribed methods for determining ALP and found the benchmarking and cost verification reports satisfactory, leading to the dismissal of the Revenue's appeal and partial allowance of the assessee's appeal. en-us Mon, 24 Jun 2019 00:00:00 +0530 Sat, 29 Jun 2019 09:38:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=382294 The tribunal determined that the international transaction involving payment for management services was at Arm's Length Price (ALP), rejecting the Transfer Pricing Officer's contention of Nil ALP for stewardship activities. It was held that separate benchmarking was required for the transaction, distinct from other international transactions. The nature of services provided was deemed as management support services, not stewardship activities, supported by detailed documentation. The tribunal emphasized the necessity of applying prescribed methods for determining ALP and found the benchmarking and cost verification reports satisfactory, leading to the dismissal of the Revenue's appeal and partial allowance of the assessee's appeal. Case-Laws Income Tax Mon, 24 Jun 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=382294