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ITAT rejected TPO’s recharacterisation of Boeing India as Full-Risk entity in technical services arrangement
Case Law Details
- Case Name
- Boeing India Defense Private Limited Vs DCIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2021-22
- Courts
- All ITAT, ITAT Delhi
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Boeing India Defense Private Limited Vs DCIT (ITAT Delhi)
Conclusion: Transfer Pricing Officer (TPO) had wrongly recharacterised Boeing India Defense Private Limited as a full-risk service provider despite the Associated Enterprise (AE) assuming the entire contractual and operational risks relating to defence support services rendered to the Indian Air Force (IAF).
Held: Assessee, a subsidiary of Boeing Company group, was engaged in rendering marketing, technical, management and construction-related support services to its Associated Enterprises (“AEs”) on a cost-plus ba...
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