Identification of arm's length price of markup for rendering of services

Last updated: 11 August 2021

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This case concerns the determination of the arm's length price (ALP) for intra-group services provided to an insurance company. The tax authorities disallowed a payment of over £40 million made to an associated enterprise, deeming the ALP to be nil. The Tribunal found that the assessee had not provided sufficient documentation to prove the necessity and receipt of these services. However, the Tribunal also ruled that additions under Section 14A of the Income Tax Act were not applicable to insurance businesses under specific provisions.

Court :
ITAT Bangalore

Brief :
This is an appeal by the assessee against the order dated 18.02.2019 of CIT(A), Bengaluru-2, Bengaluru, relating to Assessment Year 2013-14.

Citation :
ITA No.839/Bang/2019

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1 Year PLAN

1999

(Excl. of GST ₹359)

2 Years PLAN

3499

(Excl. of GST ₹629)

BEST VALUE

3 Years PLAN

4999

(Excl. of GST ₹899)

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Attached File : 1442821_4133_1627383109_final_ita_no_839_bang_2019_ms_exide_life_insurance_company_ltd__bengaluru.pdf

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Judgement posted by

Poojitha Raam Vinay

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I simplify complex income tax, TDS, banking, and investment updates into practical insights for taxpayers, salaried professionals, pensioners, and senior citizens. I regularly write on ITR filing, tax compliance, savings schemes, and the latest financial rule changes in India.

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