
Case Law Analysis
|Income Tax Appellate Tribunal
Transfer Pricing | ITAT Delhi Upholds Cost-Plus Remuneration for Limited Risk Service Providers Under Consistency Principle : ITAT Delhi
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.