https://www.taxtmi.com/caselaws?id=461422 ITAT Delhi held that TPO erred in determining arm's length price at NIL for intra-group services between assessee and associated enterprise. Court found TPO failed to properly examine evidence submitted by assessee regarding service receipt, including performance scorecards. Matter remanded to TPO for fresh determination of arm's length price using applicable transfer pricing mechanisms. Regarding comparables, tribunal upheld CIT(A)'s exclusion of CG Vak Software (failing turnover filter), Coral Hub and Cosmic Global (captive units), and EClerx Services/ICRA Online (engaged in high-end KPO services). Directed inclusion of Cepha Imaging if export earning filter satisfied and R System International if quarterly data provided. en-us Wed, 07 Aug 2024 00:00:00 +0530 Sat, 05 Apr 2025 14:05:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461422 ITAT Delhi held that TPO erred in determining arm's length price at NIL for intra-group services between assessee and associated enterprise. Court found TPO failed to properly examine evidence submitted by assessee regarding service receipt, including performance scorecards. Matter remanded to TPO for fresh determination of arm's length price using applicable transfer pricing mechanisms. Regarding comparables, tribunal upheld CIT(A)'s exclusion of CG Vak Software (failing turnover filter), Coral Hub and Cosmic Global (captive units), and EClerx Services/ICRA Online (engaged in high-end KPO services). Directed inclusion of Cepha Imaging if export earning filter satisfied and R System International if quarterly data provided. Case-Laws Income Tax Wed, 07 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461422