Case Law Analysis
|Income Tax Appellate Tribunal
Nil ALP Invalid Without Benchmarking or Proof of Economic Benefit for Intra-group Services | ITAT Ahmedabad
The ITAT Ahmedabad has struck down a Rs. 17.11 crore transfer pricing adjustment, ruling that tax authorities cannot impose a nil arm's length price for intra-group services without applying prescribed benchmarking methods or demonstrating the absence of real economic benefit. This sets a vital precedent for multinational enterprises relying on shared services, forcing tax departments to move beyond presumption and demand substantiated analysis under Section 92C.