https://www.taxtmi.com/caselaws?id=307746 The Tribunal partially allowed the assessee's appeal, directing the Assessing Officer to re-compute the income and Transfer Pricing adjustments based on the Tribunal's findings. The Tribunal disagreed with the Transfer Pricing Officer's determination of Arm's Length Price at NIL for management services charges, emphasizing the need for evidence over business necessity assessments. Additionally, the Tribunal rejected the application of a NIL ALP rate for Fully & Compulsorily Convertible Debentures, instead instructing the use of the SBI Prime Lending Rate with a 2% mark-up. The issues of unpaid leave encashment disallowance and interest levy were deemed inconsequential and not specifically addressed. en-us Mon, 31 Oct 2022 00:00:00 +0530 Wed, 03 May 2023 21:15:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307746 The Tribunal partially allowed the assessee's appeal, directing the Assessing Officer to re-compute the income and Transfer Pricing adjustments based on the Tribunal's findings. The Tribunal disagreed with the Transfer Pricing Officer's determination of Arm's Length Price at NIL for management services charges, emphasizing the need for evidence over business necessity assessments. Additionally, the Tribunal rejected the application of a NIL ALP rate for Fully & Compulsorily Convertible Debentures, instead instructing the use of the SBI Prime Lending Rate with a 2% mark-up. The issues of unpaid leave encashment disallowance and interest levy were deemed inconsequential and not specifically addressed. Case-Laws Income Tax Mon, 31 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307746