ITAT Upholds Determination of ALP on Reimbursement of Third Party Cost Incurred under CUP, Directs Deletion of Proposed Adjustment

The Mumbai bench of the Income Tax Appellate Tribunal (ITAT) upheld the determination of Arm’s Length Price (ALP) on reimbursement of third-party costs incurred under Comparable Uncontrolled Price (CUP) and directed the deletion of the proposed adjustment.     M/s. Transocean Drilling Services (I) Pvt. Ltd, the assessee company filed the returns electronically on 30/11/2012 declaring a…