https://www.taxtmi.com/caselaws?id=771063 The HC upheld the ITAT's decision to remand the matter to the TPO for fresh consideration of the transfer pricing adjustment related to intra-group services. The court found that the TPO erred in rejecting the Assessee's transfer pricing study without properly examining the value of services received. Both CIT(A) and ITAT had concluded that the Assessee received intra-group services, necessitating determination of ALP. The TPO must reassess the case considering the Assessee's transfer pricing analysis and ensure compliance with conditions under Section 92C(3) before making any adjustment. The HC found no substantial question of law and affirmed the remand for reconsideration in line with statutory requirements. en-us Mon, 05 May 2025 00:00:00 +0530 Mon, 04 Aug 2025 18:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771063 The HC upheld the ITAT's decision to remand the matter to the TPO for fresh consideration of the transfer pricing adjustment related to intra-group services. The court found that the TPO erred in rejecting the Assessee's transfer pricing study without properly examining the value of services received. Both CIT(A) and ITAT had concluded that the Assessee received intra-group services, necessitating determination of ALP. The TPO must reassess the case considering the Assessee's transfer pricing analysis and ensure compliance with conditions under Section 92C(3) before making any adjustment. The HC found no substantial question of law and affirmed the remand for reconsideration in line with statutory requirements. Case-Laws Income Tax Mon, 05 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771063