TPO cannot determine arm’s length price on estimate basis without applying any one of approved methods

Dow Corning India Pvt. Ltd. Vs. ITO (ITAT Mumbai) Undisputedly, the assessee has entered into two separate agreements with group entities for availing marketing, administrative and logistic services as well as information technology services. It is the contention of the assessee that the services were essentially required not only for carrying on the business activities but overall growth of the business, initially, in course of proceedings before the Transfer Pricing Officer, the assessee has claimed the payment made towards intra- groups services to be at arm’s length by benchmarking t...