#Arm's Length Principle

ITAT Bangalore mandates turnover-based filters and netting of receivables/payables with the same Associated Enterprise (AE) in transfer pricing comparability analysis. The ruling reinforces the arm’s length principle by preventing artificial adjustments, impacting multinational enterprises and tax professionals in benchmarking international transactions.

ITAT Delhi ruled that a limited risk service provider is entitled to cost-plus remuneration, rejecting transfer pricing adjustments where benchmarking was inconsistent and DRP directions were ignored. The decision reinforces the consistency principle in transfer pricing, impacting multinational enterprises and tax compliance strategies.