https://www.taxtmi.com/caselaws?id=765680 The ITAT Bangalore held that international transactions for business support services cannot be aggregated with other unconnected transactions when determining ALP under transfer pricing regulations. The tribunal found that transactions must be functionally or economically linked for aggregation purposes. Regarding the Most Appropriate Method, the ITAT noted the assessee failed to adequately demonstrate actual services received despite filing master agreements, invoices, and emails. The tribunal concluded there was insufficient supporting documentation to determine whether the costs represented genuine services or mere shareholder cost allocations. Consequently, the matter was remanded to the TPO for fresh adjudication without prejudice to the current findings. en-us Tue, 04 Feb 2025 00:00:00 +0530 Fri, 07 Feb 2025 08:38:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765680 The ITAT Bangalore held that international transactions for business support services cannot be aggregated with other unconnected transactions when determining ALP under transfer pricing regulations. The tribunal found that transactions must be functionally or economically linked for aggregation purposes. Regarding the Most Appropriate Method, the ITAT noted the assessee failed to adequately demonstrate actual services received despite filing master agreements, invoices, and emails. The tribunal concluded there was insufficient supporting documentation to determine whether the costs represented genuine services or mere shareholder cost allocations. Consequently, the matter was remanded to the TPO for fresh adjudication without prejudice to the current findings. Case-Laws Income Tax Tue, 04 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765680