https://www.taxtmi.com/caselaws?id=765607 ITAT Bangalore remitted transfer pricing adjustment matters to AO for fresh examination. The tribunal held that assessee failed to provide documentary evidence regarding software/tools received from associated enterprise and legal ownership of secondment employees. While acknowledging that AE's tax payments and aggregation principle arguments have merit, the tribunal emphasized these are only relevant if actual service rendition is first established through proper documentation. The tribunal rejected the benefit test application, ruling that failure to prove benefit alone cannot justify disallowances. AO was directed to recompute refund amount and provide proper credit. Appeal allowed for statistical purposes with fresh examination ordered. en-us Mon, 16 Dec 2024 00:00:00 +0530 Wed, 05 Feb 2025 08:38:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765607 ITAT Bangalore remitted transfer pricing adjustment matters to AO for fresh examination. The tribunal held that assessee failed to provide documentary evidence regarding software/tools received from associated enterprise and legal ownership of secondment employees. While acknowledging that AE's tax payments and aggregation principle arguments have merit, the tribunal emphasized these are only relevant if actual service rendition is first established through proper documentation. The tribunal rejected the benefit test application, ruling that failure to prove benefit alone cannot justify disallowances. AO was directed to recompute refund amount and provide proper credit. Appeal allowed for statistical purposes with fresh examination ordered. Case-Laws Income Tax Mon, 16 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765607