The case involves Avaya India Pvt. Ltd., which filed an appeal against the final assessment order made by the National e-Assessment Centre, Delhi. The primary disputes were related to transfer pricing adjustments concerning notional interest on overdue receivables and the arm’s length pricing of marketing support services.
The Income Tax Appellate Tribunal addressed several intricate issues, including the re-characterization of inter-company receivables and the methodology for computing arm’s length interest rates. The tribunal’s decisions reflect a detailed analysis of transfer pricing norms and the principles of natural justice in tax assessments.
The decision of the tribunal in favor of Avaya India highlights the importance of adhering to the procedural aspects of tax laws and the proper application of transfer pricing rules. This case serves as a crucial reference for similar disputes in the realm of international tax and transfer pricing.
Transfer Pricing Adjustment Case: Avaya India Pvt. Ltd. vs. ACIT, Delhi for AY 2016-17
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