https://www.taxtmi.com/caselaws?id=750807 The ITAT Delhi ruled in favor of the assessee regarding transfer pricing adjustment for administrative and agency services. The assessee had allocated common expenses between two segments and provided the basis for apportionment. The CIT(A) questioned the segmental accounts solely because they were not audited, without identifying specific defects. The ITAT held that unaudited segmental accounts cannot be deemed untrustworthy without pointing to particular errors. The court rejected the CIT(A)'s observation about non-allocation of non-compete fees and goodwill, noting the TPO also failed to allocate these expenses. The ITAT directed the AO to delete the impugned adjustment and allowed the assessee's appeal. en-us Thu, 07 Mar 2024 00:00:00 +0530 Fri, 29 Mar 2024 23:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=750807 The ITAT Delhi ruled in favor of the assessee regarding transfer pricing adjustment for administrative and agency services. The assessee had allocated common expenses between two segments and provided the basis for apportionment. The CIT(A) questioned the segmental accounts solely because they were not audited, without identifying specific defects. The ITAT held that unaudited segmental accounts cannot be deemed untrustworthy without pointing to particular errors. The court rejected the CIT(A)'s observation about non-allocation of non-compete fees and goodwill, noting the TPO also failed to allocate these expenses. The ITAT directed the AO to delete the impugned adjustment and allowed the assessee's appeal. Case-Laws Income Tax Thu, 07 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=750807