Intra-group IT/marketing support services and CSR donation deductions upheld; transfer pricing NIL ALP and PF delay disallowance set aside.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Transfer pricing adjustment on intra-group IGS/ITSS was deleted because the services were not mere stewardship/shareholder activities and the evidence showed the payments were incurred for business benefit and were at arm's length; consequently, the TPO's NIL ALP determination was unsustainable. Transfer pricing adjustment on marketing support services was also deleted as TNMM, consistently accepted in earlier years, remained the most appropriate method, and CUP was wrongly applied due to lack of stringent functional/product/market comparability. Disallowance of employees' PF contribution for a one-day delay was directed to be rectified as the DRP had already required corrective action, and the AO was ordered to pass a rectification after h.........