Pass-Through Costs Excluded From Transfer Pricing PLI as No Value Addition Was Performed: ITAT Mumbai

Unilever Industries Private Limited Vs ACIT (ITAT Mumbai) The appeal before the Income Tax Appellate Tribunal (ITAT), Mumbai Bench, arose from the final assessment order for Assessment Year 2023-24 involving transfer pricing adjustments, royalty attribution, foreign tax credit, education cess withdrawal, and computational issues. The assessee, a wholly owned subsidiary of a UK-based group company, was engaged in providing research and development services, enterprise and technology support services in the nature of business support services and back-office support services, and design services...