Transfer Pricing - ITAT Allows KBS Creations’ Appeal, Rules No Transfer Pricing Adjustment Without Proved ‘Arrangement’ Under Section 80IA(10)

The Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) has set aside a transfer pricing (TP) adjustment of Rs. 10.98 crore and ruled that the Assessing Officer (AO) failed to establish an arrangement between the assessee and its associated enterprise (AE) as required under Section 80IA(10) of theIncome Tax Act, 1961.