Matter remanded as TP adjustment could not be at ‘NIL’ as determined by TPO

American Express Banking Corp Vs ADIT (ITAT Delhi)

Conclusion: Transfer Pricing Officer ( TPO ) had erred in setting the Arm’s Length Price ( ALP ) for Intra Group Services at NIL for assessee as he failed to determine ALP by applying applicable transfer pricing mechanism as per Income Tax Rules and determine the TP A

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