Intra-Group Services Allowed as Genuine – ALP Review Sent Back to TPO

Sempertrans India Private Limited Vs ITO (ITAT Pune)

Intra-Group Services Allowed as Genuine – ITAT Holds Services Were Actually Received; Restores ALP Examination to TPO

Pune Tribunal examined disallowance of Rs.5,66,05,177/- relating to Intra-Group Services paid to AE ‘Semperit Aktiengesellschaft Holding (SAH)’. AO framed assessment u/s 144 r.w.s. 260 r.w.s. 144B based on TPO’s finding that the Assessee did not receive any real services & therefore ALP of the IGS was ‘Nil’. DRP upheld the TPO’s view, further directing alternate disallowance u/s 37 on the

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