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

Last updated: 11 August 2021
Quick Summary
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

Daily Limit Reached

You have reached your daily limit of 2 Free Judgements

Subscribe to CCI PRO for unlimited access

Why Upgrade to CCI PRO?
  • No Ads
  • WhatsApp Broadcasts
  • Daily E-Newsletter
  • Unlimited Judgements Access
BEST VALUE
2 YEAR PLAN
3,499
(Inclusive of GST)
1 YEAR PLAN
1,999
(Inclusive of GST)
View all CCI PRO benfits

Already a PRO member? Login here for an ad-free experience.

 
Comments


Recent Judgments :

  1. Forest Development Tax Demand, Collection and Refund Subject to Final Outcome of Pending Cases
  2. Forest Development Tax Demand, Collection and Refund Subject to Final Outcome of Pending Cases
  3. SC : Extended Limitation Cannot Be Invoked Where Department Was Aware of Valuation Facts
  4. SC : Selling Shares While in Possession of UPSI Constitutes Insider Trading Even if No Profit Is Made
  5. SC : Laser Imagers Compatible with Machines Under Different Tariff Headings Classifiable Under CTH 9033
  6. Education Consultancy Services to Foreign Universities Not Intermediary Services; Refund of IGST on Export of Services Allowed
  7. Penalty Cannot Be Confirmed Beyond What is Specified in Statutory Form GST DRC-01
  8. Non-Supply of Field Visit Report Vitiates Rejection of Revocation Application
  9. Alternative Remedy before GSTAT to be Exhausted Despite Allegation that Adjudication Travelled Beyond SCN
  10. ITAT Jodhpur: AO Allows ₹2.61 Crore Deduction under Sections 54EC and 54F; Assessee's Appeal Dismissed as Infructuous

View More Judgments »


Trending Online Classes

view all classess

CCI Pro
Meet our CAclubindia PRO Members
Pro Member Jai SolankiJai SolankiPro Member Vinod SelvVinod SelvPro Member Chnmaya parhiChnmaya parhiPro Member Ravinder paruthiRavinder paruthiPro Member Anjum AshrafAnjum Ashraf
Subscribe to Pro
Join an elite circle of professionals

Browse by Category