The Ahmedabad Bench of Income-tax Appellate Tribunal, in the case of: SABIC Innovative Plastics India Pvt Ltd. (ITA No. 1125/Ahd/2014 – Assessment Year 2009-10 and IT (TP) No. 427/Ahd/16 – Assessment Year 2011-12), deleted the adjustment made by the Transfer Pricing Officer (TPO) Dispute Resolution Panel (DRP) with respect to payment for intra-group services to associated enterprises of the taxpayer.
The Tribunal rejected the Nil Arm’s Length Price determined by TPO with respect to management services under Comparable Uncontrolled Price Method (CUP).