ITAT Directs TPO to Reassess Intra-Group Service Payments and Arm’s Length Pricing due to Insufficient Evidence

The ITAT directed the Transfer Pricing Officer (TPO) to reassess intra-group service payments and arms-length pricing due to insufficient evidence. The tribunal found that the TPO’s initial transfer pricing assessment lacked proper documentation and evidence to support the pricing of intercompany services. The decision requires the TPO to reassess the arms-length pricing for these transactions, reinforcing the need for accurate and detailed documentation in transfer pricing cases. The ruling emphasizes the importance of transparency and proper evidence in evaluating intra-group service transactions for tax purposes.