https://www.taxtmi.com/caselaws?id=775614 ITAT Ahmedabad held that the head office and its Indian PE qualify as associated enterprises under Section 92A(2)(g) of the Income Tax Act. The PE is not independent in capital, control, or management from the head office, warranting transfer pricing adjustments. The ALP was determined using the most appropriate method, rejecting the CUP method due to the onshore agreement not being at arm's length. The assessee's arguments against PE status of individuals and entities involved were dismissed for lack of merit. The project office and related entities were confirmed as PEs of the foreign enterprise in India. Consequently, the international transactions executed by the PE were subject to transfer pricing adjustments, resulting in an ALP adjustment of Rs. 22 Crores upheld by the Tribunal. en-us Tue, 22 Jul 2025 00:00:00 +0530 Mon, 28 Jul 2025 08:27:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775614 ITAT Ahmedabad held that the head office and its Indian PE qualify as associated enterprises under Section 92A(2)(g) of the Income Tax Act. The PE is not independent in capital, control, or management from the head office, warranting transfer pricing adjustments. The ALP was determined using the most appropriate method, rejecting the CUP method due to the onshore agreement not being at arm's length. The assessee's arguments against PE status of individuals and entities involved were dismissed for lack of merit. The project office and related entities were confirmed as PEs of the foreign enterprise in India. Consequently, the international transactions executed by the PE were subject to transfer pricing adjustments, resulting in an ALP adjustment of Rs. 22 Crores upheld by the Tribunal. Case-Laws Income Tax Tue, 22 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775614