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 Adjustment hence, he was directed to reconsider the ALP by evaluating all the evidence afresh.

Held: Assessee was a non resident company incorporated under the laws of USA and engaged in the banking business. During the assessm

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