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 Good

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