Transfer pricing disallowance as assessee failed to prove any benefit not justifiable: ITAT Bangalore

Bosch Automotive Electronics Indi Private Limited Vs DCIT (ITAT Bangalore) ITAT Bangalore held that merely because the assessee has failed to prove any benefit from services received the disallowance of transfer pricing cannot be made. Accordingly, one more opportunity granted to assessee to prove the case. Facts- During scrutiny assessment, reference was made to TPO for computation of arm’s length price in relation to the international transactions. TPO passed the TP order under section 92CA (3) of the Act dated on 14 July 2023 (‘TP Order’) proposing an adjustment of INR 130...