Notional Income Winding-Up Costs Not Taxable in Transfer Pricing: ITAT Delhi

Motricity India Private Limited Vs DCIT (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT), Delhi, delivered a significant ruling on January 10, 2025, in the case of Motricity India Pvt. Ltd. v. DCIT (ITA No. 1092/DEL/2023), addressing critical aspects of transfer pricing, winding-up costs, and the taxation of deemed income under the Income Tax Act, 1961. The case, involving Motricity India Pvt. Ltd., a wholly-owned subsidiary of Motricity Pte. Ltd., Singapore, sets a significant precedent for companies terminating service agreement with their AE and / or ceasing operations under adverse bu...