|Income Tax Appellate Tribunal
Transfer Pricing: Management Charges Adjustments Quashed for Violating Section 92C(3)(c) & Aggregation Precedent | ITAT Delhi
ITAT Delhi has struck down transfer pricing adjustments on management charges, royalty, and receivables interest, holding that the tax authority erred by ignoring the assessee’s aggregation methodology and failing to prove lack of tangible benefit under Section 92C(3)(c), reinforcing Kusum Healthcare’s principle that commercial wisdom must be respected. This ruling empowers MNEs with robust TP documentation to resist arbitrary disallowances based on speculative benefit assessments.