SC Upholds ITAT Remand in Transfer Pricing Dispute on Intra-Group Services

American Express Banking Corporation (India Branch) Vs Assistant Director of Income Tax (Supreme Court of India) Supreme Court: Dismisses assessee’s SLP on ALP remand of intra-group services Facts: The petitioner is American Express Banking Corporation (India Branch) (the ‘assessee’). The respondent is the Assistant Director of Income Tax, Circle 1(1), International The matter concerns transfer-pricing adjustments relating to intra-group services (IGS) and the computation of Arm’s-Length Price (ALP). The Transfer Pricing Officer (TPO) made an ALP adjustment in respect of intra-group s...