https://www.taxtmi.com/caselaws?id=416484 Transfer pricing adjustment on business support cost could not be conclusively upheld or discarded on the record as the invoice and supporting workings did not show any bifurcation of direct cost, business support cost, or the mark-up applied. The assessee claimed that the invoice to the associated enterprise already included 12% mark-up on all costs, but the material produced did not substantiate that claim. The matter was therefore restored to the Commissioner (Appeals) for fresh adjudication after giving the assessee an opportunity to produce proper evidence showing that all costs had been remunerated with the stated mark-up. en-us Thu, 23 Dec 2021 00:00:00 +0530 Thu, 30 Dec 2021 08:32:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=416484 Transfer pricing adjustment on business support cost could not be conclusively upheld or discarded on the record as the invoice and supporting workings did not show any bifurcation of direct cost, business support cost, or the mark-up applied. The assessee claimed that the invoice to the associated enterprise already included 12% mark-up on all costs, but the material produced did not substantiate that claim. The matter was therefore restored to the Commissioner (Appeals) for fresh adjudication after giving the assessee an opportunity to produce proper evidence showing that all costs had been remunerated with the stated mark-up. Case-Laws Income Tax Thu, 23 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=416484