Transfer Pricing – Reimbursement of incentive paid to employees through Indian co.

M/s. Aricent Technologies (Holding) Limited Vs. DCIT (ITAT), Dated: 21st Jan 2011 Transfer Pricing: Reimbursement of incentive paid to employees through Indian co. Extract The TPO in his order held that the payment of incentive to employees is towards technical services rendered by the assessee to the AE and that the AE has entered into such transaction to avoid paying a mark-up on the payments. In the transfer pricing documentation, since the assessee had shown its operating profit margin at 27.95% (OP/TC), the TPO considering such margin, notionally imputed a markup on the said sum of `10,...