No TP addition in respect of international transaction of payment of Regional Service Charges in case value within tolerance range

Goodyear South Asia Tyres Private Limited Vs ACIT (ITAT Pune) Conclusion: No transfer pricing addition in respect of international transaction of payment of Regional Service Charges pertaining to five intra-group services could be made because even if presume that the comparable uncontrolled transaction was at zero mark-up, still the value of the international transaction was within the notified tolerance range. Held: Assessee was an Indian company engaged in the manufacturing of Goodyear branded Medium, Commercial truck tyres, etc. Return of income was furnished declaring total income of Rs.7...