Adhoc adjustment without any defect identified by TPO in TP analysis not justified

Siemens Aktiengesellschaft Vs ACIT (International Tax) (ITAT Mumbai)

ITAT Mumbai held that in absence of any contrary inference by Transfer Pricing Officer [TPO] in the TP analysis, ad hoc disallowance cannot be restored towards the international transaction of technical service and other transaction. Accordingly, appeal allowed.

Facts- AO noted that the assessee is a non-resident and that the assessee had derived income of Royalty for technical knowhow Fee for Technical assistance under various agreements from Indian AE. Accordingly, reference was made to

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