Transfer Pricing Adjustment Deleted for Cost-to-Cost Reimbursements: ITAT Chennai

Fuji Electric India Private Limited Vs DCIT (ITAT Chennai)

The appeal before the Income Tax Appellate Tribunal Chennai concerned assessment year 2020–21 and challenged additions and adjustments made pursuant to a transfer pricing order and the final assessment passed after DRP directions. The Tribunal first condoned a delay of 160 days in filing the appeal, accepting the assessee’s explanation of administrative changes.

On transfer pricing, the dispute related to an adjustment of ₹7,96,238 on reimbursements made by an associated enterprise for expenses

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