https://www.taxtmi.com/caselaws?id=767700 The ITAT Delhi ruled on transfer pricing adjustments for intra-group services and fixed asset purchases. For IGS, the tribunal followed coordinate bench precedent, directing deletion of adjustments as receipts from IT and administrative services to Indian affiliate were not fees for technical services under India-Singapore DTAA. Regarding fixed asset purchases used partly for demonstration and partly for trading, the tribunal noted TPO accepted trading segment ALP. Since assets were capitalized and depreciation claimed, the matter was remanded to AO/TPO to verify demonstration asset costs versus traded goods input costs and redetermine ALP after proper hearing. en-us Wed, 19 Mar 2025 00:00:00 +0530 Sat, 22 Mar 2025 08:34:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767700 The ITAT Delhi ruled on transfer pricing adjustments for intra-group services and fixed asset purchases. For IGS, the tribunal followed coordinate bench precedent, directing deletion of adjustments as receipts from IT and administrative services to Indian affiliate were not fees for technical services under India-Singapore DTAA. Regarding fixed asset purchases used partly for demonstration and partly for trading, the tribunal noted TPO accepted trading segment ALP. Since assets were capitalized and depreciation claimed, the matter was remanded to AO/TPO to verify demonstration asset costs versus traded goods input costs and redetermine ALP after proper hearing. Case-Laws Income Tax Wed, 19 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767700