Benchmarking of cost to cost reimbursement of expenses was not within TPO jurisdiction

Danisco India Pvt. Ltd. Vs DCIT (ITAT Delhi)

 In the present set of facts where the assessee was availing specialized services which were provided by the AEs from common pool and the evidences in this regard have been filed by the assessee and where the services were charged on cost to cost basis, there is no merit in the order of the Assessing Officer in questioning the availment of services and the benefit derived by the assessee. It may be pointed out that the Assessing Officer in the alternate held that

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