Captive Service Provider Entitled to Risk Adjustment; Nil ALP for Proven Intra-Group Services Rejected: ITAT Delhi

Corning Technologies India Pvt. Ltd. Vs DCIT (ITAT Delhi) The assessee appealed against the assessment order passed under sections 143(3) read with 144C of the Income-tax Act, 1961, challenging transfer pricing (TP) adjustments relating to market support services and administrative support services. The Assessing Officer (AO), following the Transfer Pricing Officer’s (TPO) order and the Dispute Resolution Panel (DRP)’s directions, made adjustments of ₹34.67 lakh in respect of market support services and ₹3.15 crore in respect of intra-group administrative support services. The ...