Determination of ALP of intra group services as NIL not sustained as reasonable documents maintained

Lintas India Private Limited Vs ACIT (ITAT Mumbai) ITAT Mumbai held that determination of Arm’s Length Price (ALP) of intra group services at Rs. Nil is not justified as the assessee has maintained a reasonably sound documentation of intra group services. Facts- the assessee is engaged in the business of advertising business and offer services related to advertising media planning services, marketing services, public relations etc. to its clients. As the assessee has entered into international transactions being part of Lowe worldwide group with its Associated Enterprises as assessee is ...