Reimbursement Transactions Remanded for De Novo TP Examination

Corporate Worldwide Stay LLP Vs Assessment Unit (ITAT Mumbai) ITAT Mumbai: TP Adjustment on Alleged Reimbursement Transactions Set Aside for Fresh FAR Analysis The Mumbai ITAT (K Bench) dealt with transfer pricing adjustments made in the case of Corporate Worldwide Stay LLP for AY 2020-21, arising from transactions with its Associated Enterprise (AE) in Mauritius. The TPO had treated reimbursement of booking and accommodation expenses as an international transaction, applied the Profit Split Method (PSM), and attributed a substantial portion of AE’s profits to the Indian LLP. The DRP partly ...