Dismissing the appeal of the Revenue High Court held that order ITAT is justified in in directing to adopt 16.63% Arm’s Length margin for transaction relating to non US entities based on MAP concluded with US Tax Authorities. Followed P CIT v. J.P. Morgan Services India (P.) Ltd (2019) 263 Taxman 141 (Bom)(HC)
PCIT v. J.P. Morgan Services India (P.) Ltd. (2020) 119 taxmann.com 413 (Bom.)(HC) Editorial: SLP of revenue is dismissed, PCIT v. JPMorgan Services India (P) Ltd (2020) 274 Taxman 281 (SC)
S. 92C : Transfer pricing-Arm’s length price-Adjustment-MAP-ITAT is justified in in directing to adopt 16.63% Arm’s Length margin for transaction relating to non US entities based on MAP concluded with US Tax Authorities.