TP adjustment under MAP cannot be applied to other international transaction

AON Consulting Pvt. Ltd Vs PCIT – 1 And Ors. (Delhi High Court)

Delhi High Court held that MAP (Mutual Agreement Procedure) is based on consensus between the competent authorities of the contracting states and the basis for TP adjustments under the MAP cannot be applied to international transactions, which are not subject of negotiations under the MAP.

Facts- Hewitt Associates (India) Private Limited (since merged with the appellant) had filed the said appeal assailing the transfer pricing adjustment. The said TP adjustment was in two parts. One that relat

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