TNMM appropriate method for determining Arm’s Length Price of management fees

Schaeffler India Ltd. Vs ACIT (ITAT Ahmedabad)

ITAT Ahmedabad held that that the activities / services do not qualify as stewardship / shareholder activity. Further, assessee correctly determined Arm’s Length Price in respect of management fees by using Transaction Net Margin Method i.e. TNMM.

Facts- The assessee company had paid management fees to Schaeffler Holding China Company (“Associated Enterprise”) and bench-marked the transaction by using TNMM. The Transfer Pricing Officer determined ALP of the transaction at Rs. NIL by treating the services p

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