https://www.taxtmi.com/caselaws?id=294771 Upward transfer pricing adjustment for intra-group support services was held unsustainable where the assessee produced agreements, time sheets, debit notes and other contemporaneous records showing actual receipt of services, cost allocation with mark-up, and business necessity. The assessee's dependence on the associated enterprise for procurement, sales, compliance, financial and tax support, together with evidence that the services were not duplicative and enabled operations, supported deletion of the adjustment. Following similar facts in an earlier year, the coordinate bench had also deleted a comparable adjustment. The adjustment was directed to be deleted in favour of the assessee. en-us Mon, 14 Sep 2020 00:00:00 +0530 Sat, 01 May 2021 17:54:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=294771 Upward transfer pricing adjustment for intra-group support services was held unsustainable where the assessee produced agreements, time sheets, debit notes and other contemporaneous records showing actual receipt of services, cost allocation with mark-up, and business necessity. The assessee's dependence on the associated enterprise for procurement, sales, compliance, financial and tax support, together with evidence that the services were not duplicative and enabled operations, supported deletion of the adjustment. Following similar facts in an earlier year, the coordinate bench had also deleted a comparable adjustment. The adjustment was directed to be deleted in favour of the assessee. Case-Laws Income Tax Mon, 14 Sep 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=294771