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Assessee, an Indian Company, a subsidiary of a Mauritian company, provided buying services to its AEs. It paid service charges at costs with a 8% markup. TPO noticed that assessee was allowed commission @8% on costs incurred for its sourcing activities. TPO changed base from costs incurred to FOB value of exports on which 8% markup was charged. DRP restricted it to 6%. ITAT quashed the shifting the base of markup, and the addition by AO. ...
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