https://www.taxtmi.com/caselaws?id=462530 ITAT Ahmedabad partially allowed the assessee's appeal on TP adjustments. For global and regional head office services, the tribunal ruled that TPO erred in determining ALP at "Nil" without applying prescribed benchmarking methods, noting that once service receipt is demonstrated, TP adjustment without proper benchmarking is unsustainable. However, regarding contract R&D services to overseas entity, the tribunal confirmed the addition as assessee charged lower margin than 29% specified in the contract agreement. en-us Tue, 11 Oct 2022 00:00:00 +0530 Sat, 28 Jun 2025 14:55:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462530 ITAT Ahmedabad partially allowed the assessee's appeal on TP adjustments. For global and regional head office services, the tribunal ruled that TPO erred in determining ALP at "Nil" without applying prescribed benchmarking methods, noting that once service receipt is demonstrated, TP adjustment without proper benchmarking is unsustainable. However, regarding contract R&D services to overseas entity, the tribunal confirmed the addition as assessee charged lower margin than 29% specified in the contract agreement. Case-Laws Income Tax Tue, 11 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462530