TMI Blog2021 (9) TMI 1361X X X X Extracts X X X X X X X X Extracts X X X X ..... t the issue raised in this appeal is similar to the one raised in the Revenue s appeal for the immediately preceding assessment year, 2009-10. Except for increase in mark-up rate under the two agreements, both the sides fairly conceded, that nature of the services is unchanged. The appeal for the assessment year 2009-10 was fixed simultaneously with the extant appeal. During the course of hearing ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... we countenance the impugned order on this score. It is made clear that the Revenue has challenged only the ascertainment of the nature of services by the ld. first appellate authority and not the ALP determination of the international transaction by the ld. CIT(A). - ITA No.1219/PUN/2017 - - - Dated:- 30-9-2021 - SHRI R.S. SYAL, VICE PRESIDENT AND SHRI S.S. VISWANETHRA RAVI, JUDICIAL MEMBE ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eipt of Headquarter services from Nalco, USA and Management Assistance services from Nalco Pacific Pte Ltd., Singapore totaling worth ₹ 17,21,93,000/- were reported. The Assessing Officer (AO) made a reference to the Transfer Pricing Officer (TPO) for determining the Arm s Length Price (ALP) of the international transactions. The TPO took note of the relevant clauses of the agreements entere ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 4. We have heard the rival submissions and gone through the relevant material on record. It is common submission by both the sides that the issue raised in this appeal is similar to the one raised in the Revenue s appeal for the immediately preceding assessment year, 2009-10. Except for increase in mark-up rate under the two agreements, both the sides fairly conceded, that nature of the services i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng from the ground extracted above, is only on the nature of the services, following our view taken for the immediately preceding year, we countenance the impugned order on this score. 5. It is made clear that the Revenue has challenged only the ascertainment of the nature of services by the ld. first appellate authority and not the ALP determination of the international transaction by the ld. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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