ITAT upheld determination of ALP as nil for duplicative services

DCIT Vs Teradata India Pvt. Ltd. (ITAT Delhi) Subvention Fee consider in Distribution Segment for calculating Segment wise Margin The issue under consideration is whether the TPO is correct in considering subvention fee in the BPO segment instead of distribution segment? ITAT states that, assessee operate as a limited risk distributor and is assured 3% operating profit margin for its distribution activity. Any shortfall in the margin is made good by its AE by payment of subvention fee. During the year the assessee received subvention fee of Rs.21,75,54,831/-. While working out the margin of th...