Transfer Pricing: ITAT Delhi Favors Segmental ALP, Rejects Notional Interest

Opterna Technologies Private Limited Vs Assessment Unit (National Faceless Assessment Centre)(‘NFAC’) Deputy/ACIT (ITAT Delhi)

ITAT Delhi directs segment-wise ALP, includes Fiberfox comparable and rejects notional interest on AE dues for Opterna Technologies, remits Section 68 issue.

Overview: This case involves an appeal by Opterna Technologies Private Limited against an order from the Assessment Unit (National Faceless Assessment Centre) for the assessment year 2020-21. The appeal was heard by the Income Tax Appellate Tribunal (ITAT)

Please become a Premium member. If you are already a Premium member, login here to access the full content.