https://www.taxtmi.com/caselaws?id=448633 ITAT Mumbai ruled in favor of the assessee regarding transfer pricing adjustment on shared service charges paid to associated enterprises. The TPO had determined arm's length price at nil and made adjustment for entire payment. However, ITAT found that lower authorities failed to search for similar uncontrolled transactions between non-associated enterprises. Following OECD guidelines and precedent from Jabil Circuit India case, ITAT held that when services from AEs are substantiated by documentary evidence and cost allocation uses well-accepted allocation key methods, no transfer pricing adjustment is warranted. Appeal allowed. en-us Tue, 26 Dec 2023 00:00:00 +0530 Wed, 24 Jan 2024 10:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448633 ITAT Mumbai ruled in favor of the assessee regarding transfer pricing adjustment on shared service charges paid to associated enterprises. The TPO had determined arm's length price at nil and made adjustment for entire payment. However, ITAT found that lower authorities failed to search for similar uncontrolled transactions between non-associated enterprises. Following OECD guidelines and precedent from Jabil Circuit India case, ITAT held that when services from AEs are substantiated by documentary evidence and cost allocation uses well-accepted allocation key methods, no transfer pricing adjustment is warranted. Appeal allowed. Case-Laws Income Tax Tue, 26 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448633