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TRANSFER PRICING – COMPUTATION OF ARM’S LENGTH PRICE

Adjustment : Where TPO determined ALP of payment made by assessee towards ‘intra-group services’ at Rs. Nil on ground that assessee failed to demonstrate that it had received services or that it had benefited from such services as claimed, since assessee could not file all documents before TPO due to short period of time allowed and Covid-19 pandemic, additional evidences filed by assessee after TPO proceedings were to be admitted and matter was to be remanded back for fresh adjudication – Limagrain India (P.) Ltd. v. National Faceless Assessment Centre – [2024] 158 taxmann.com 548 (Indore – Trib.)

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