Judgement

The ITAT Delhi holds that once Section 92BA(i) was omitted, proceedings initiated under the omitted provision cannot survive
 


ITAT Rules Omission of Section 92BA(i) Invalidates Transfer Pricing Proceedings

ITAT deleted Rs 1,305 crore in transfer pricing and corporate tax additions against LG Electronics India across five financial years.

The ITAT Delhi holds that ALP cannot be determined at Nil without comparable uncontrolled transactions


The ITAT Delhi ruled that the arm's length guarantee commission should be restricted to 0.5% instead of 1.3% adopted by the Transfer Pricing Officer.

The ITAT Delhi has deleted a transfer pricing adjustment of Rs 5.19 crore towards AMP expenditure.

The ITAT rejects fragmented transfer pricing analysis and remands benchmarking of interlinked business transactions for fresh examination.