ITAT Rejects Arbitrary Transfer Pricing Adjustments on Management Services

Virinchi Ltd Vs DCIT (ITAT Hyderabad) TPO Cannot Question Commercial Expediency- ITAT Hyderabad Deletes ₹10 Cr TP Addition – AE Services Held Genuine Virinchi Ltd, a listed company engaged in IT solutions & software development, filed appeal against the final assessment order passed u/s 143(3) r.w.s. 144C(3) for AY 2021-22, based on DRP directions. The first issue raised was that the assessment order dated 09.10.2024 was barred by limitation u/s 153. The Tribunal noted that this legal question is pending before the Supreme Court in the case of CIT Vs Roca Bathroom Products (P) Ltd, whe...