Gemplus India (P) Ltd. v. ACIT
3 Taxmann.com 755Income Tax Appellate Tribunal2010#5889 most cited
What is Gemplus India (P) Ltd. v. ACIT authority for?
The Assessing Officer (AO) may determine the Arm's Length Price (ALP) to be 'Nil' for intra-group services if the services were not actually rendered or if the payment is not commensurate with the benefits derived. This position aligns with the Gemplus India case where management fees were challenged.
20
judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2017 to 2026.
Also referred to as
Gemplus India (P) Ltd. v. ACIT · transfer pricing · arm's length price · ALP · intra-group services · management fees · associated enterprises · section 92CA · section 92C