https://www.taxtmi.com/caselaws?id=759026 The ITAT Delhi held that the assessee successfully established actual rendering of technical support services (TSS) and business support services (BSS) as per agreements, which were necessary for day-to-day business operations. The TPO erred in determining arm's length price as NIL for these services. The DRP failed to properly consider the assessee's objections and additional evidence as directed by the Appellate Tribunal in the first round. The TPO violated consistency principles by deviating from aggregation approach accepted in previous assessment years without providing detailed reasons. Regarding royalty transactions, the TPO incorrectly computed arm's length price without considering landed costs of imported components in comparables. The matter was remitted back for fresh determination. en-us Thu, 29 Aug 2024 00:00:00 +0530 Fri, 20 Sep 2024 13:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759026 The ITAT Delhi held that the assessee successfully established actual rendering of technical support services (TSS) and business support services (BSS) as per agreements, which were necessary for day-to-day business operations. The TPO erred in determining arm's length price as NIL for these services. The DRP failed to properly consider the assessee's objections and additional evidence as directed by the Appellate Tribunal in the first round. The TPO violated consistency principles by deviating from aggregation approach accepted in previous assessment years without providing detailed reasons. Regarding royalty transactions, the TPO incorrectly computed arm's length price without considering landed costs of imported components in comparables. The matter was remitted back for fresh determination. Case-Laws Income Tax Thu, 29 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759026