TP Adjustment Quashed as Benefit Test Cannot Justify NIL ALP After Service Receipt Is Established

Roquette India Pvt. Ltd. Vs A/DCIT (ITAT Ahmedabad) The assessee, a wholly owned subsidiary of a French company, was engaged in the manufacture of starch derivatives, glucose, maltodextrins, and related products in India. For Assessment Years 2017-18 and 2018-19, the Transfer Pricing Officer (TPO) proposed adjustments by determining the Arm’s Length Price (ALP) of intra-group services received from Associated Enterprises (AEs) at NIL. The disputed services comprised Central Corporate and Area (CCA) services, Global Business Unit (GBU) services, and Information Technology (IT) services. The a...