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Transfer Pricing: ITAT Delhi Favors Segmental ALP, Rejects Notional Interest
Case Law Details
- Case Name
- Opterna Technologies Private Limited Vs Assessment Unit (National Faceless Assessment Centre)(‘NFAC’) Deputy/ACIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2020-21
- Courts
- All ITAT, ITAT Delhi
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Opterna Technologies Private Limited Vs Assessment Unit (National Faceless Assessment Centre)(‘NFAC’) Deputy/ACIT (ITAT Delhi)
ITAT Delhi directs segment-wise ALP, includes Fiberfox comparable and rejects notional interest on AE dues for Opterna Technologies, remits Section 68 issue.
Overview: This case involves an appeal by Opterna Technologies Private Limited against an order from the Assessment Unit (National Faceless Assessment Centre) for the assessment year 2020-21. The appeal was heard by the Income Tax Appellate Tribunal (ITAT) Delhi Bench, with the order pronounced on May 7, 2025...
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