https://www.taxtmi.com/caselaws?id=753801 ITAT Indore allowed the assessee's appeal in a transfer pricing case. The TPO had determined the arm's length price (ALP) of impugned transactions at Rs. Nil, finding insufficient proof that services were actually received. The assessee cited COVID-19 constraints and only five days allowed by TPO for document submission. ITAT admitted additional evidence under Rule 29, noting it was substantial and critical to the case. The matter was remanded to AO/TPO for fresh consideration with proper opportunity for submissions. ITAT also directed authorities to consider the 3% benefit under Section 92C(2) proviso, which is a mandatory statutory provision. en-us Fri, 19 Jan 2024 00:00:00 +0530 Mon, 10 Jun 2024 12:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753801 ITAT Indore allowed the assessee's appeal in a transfer pricing case. The TPO had determined the arm's length price (ALP) of impugned transactions at Rs. Nil, finding insufficient proof that services were actually received. The assessee cited COVID-19 constraints and only five days allowed by TPO for document submission. ITAT admitted additional evidence under Rule 29, noting it was substantial and critical to the case. The matter was remanded to AO/TPO for fresh consideration with proper opportunity for submissions. ITAT also directed authorities to consider the 3% benefit under Section 92C(2) proviso, which is a mandatory statutory provision. Case-Laws Income Tax Fri, 19 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753801