TPO cannot value actual intra-group services at ‘Nil’ based on a subjective ‘benefit test’, and sequential commercial disallowance under section 37(1) cannot survive if the TP adjustment is deleted.
TPO cannot value actual intra-group services at ‘Nil’ based on a subjective ‘benefit test’, and sequential commercial disallowance under section 37(1) cannot survive if the TP adjustment is deleted. Issue Whether the Transfer Pricing Officer (TPO) was legally justified in determining the Arm’s Length Price (ALP) of intra-group services at ‘Nil’ based on a subjective… Read More »