Case Number: ITA 5203/DEL/2019
Appellant: Danisco India Pvt. Ltd., Gurugram
Respondent: DCIT, Circle-7(1), New Delhi
Assessment Year: 2013-14
Order Type: Final Tribunal Order
Date of Order: May 5, 2021
Case Filed on: June 6, 2019
Pronounced on: May 5, 2021
The case involves multiple appeals and cross-appeals related to Transfer Pricing Adjustments for Assessment Years 2010-11 to 2013-14. The main contention revolves around the nature of Intra Group Services, particularly management services availed by Danisco from its associated enterprises and the respective Transfer Pricing Adjustments.
The Tribunal addressed the issue of whether the services availed by Danisco were purely shareholder activities and if the costs associated with them were justified. The decisions explored the intricacies of shared support services, marketing, and technical assistance services, ultimately leading to a detailed analysis of the Transfer Pricing Adjustments.
This case highlights the challenges in classifying Intra Group Services in Transfer Pricing Adjustments and the impact of such classifications on multinational corporations. The Tribunal’s decision provides clarity on handling similar disputes and the criteria for evaluating the arm’s length nature of transactions between associated entities.
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