2025 (7) TMI 1303

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....olution Panel (DRP) dated 08.05.2024 and order passed by Transfer Pricing Officer (TPO) under section 92CA(3) dated 30.05.2024 under section 144C(5) of the Income Tax Act, 1961 (for short 'the Act') qua the assessment year 2020-21. 2. Ground No. 1 raised by the assessee is general in nature and does not require any specific adjudication. 3. The Ground Nos. 2 and 2.2 raised by the assessee are challenging the transfer pricing adjustment of Rs. 21,44,324/- made by the ld TPO/ AO by re-characterizing the recovery of expenses from Associated Enterprises (AEs) as provision for Business Support Services. 4. We have heard the rival submissions and perused the material available on record. The assessee company was incorporated in 1993 in India. ....

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....ions of the ld DRP, the transfer pricing adjustment on this count after applying mark up of 11.17% was made at Rs. 21,44,324/-. 5. Before us, the ld AR drew our attention to pages 31 and 35 of the Paper Book together with pages 39 and 41 of the order of ld TPO to drive home the point that assessee had indeed incurred certain expenses on behalf of its AEs and had sought reimbursement of the same on actual basis without having any mark up thereon in the debit note raised on the AEs which has been inadvertently mentioned as business support services. It is pertinent to note that in the said debit note, though it was mentioned as business support services inadvertantly, the assessee had clearly mentioned under the column of mark up as Nil. Thi....