In its petition before the High Court, filed through advocates Anuj Jhaveri and Mihir Modi, PayPal had stated that it had initially received a notice for the computation of arm’s length price (ALP) for AY 2020-21.
On July 29, the ACIT Mumbai passed a transfer pricing order whereby an adjustment of over ₹91 crores was made for the distribution of payment services in India and a penalty notice was also issued.
On October 17, the Income Tax review unit made an addition of ₹91 crores to the assessed income of PayPal and the final assessed income came to over ₹104 crores.
The same day, a demand notice was issued demanding over ₹32.39 crores within 30 days of the notice on grounds of underreporting PayPal’s income.
Source: Barandbench
