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2012 (10) TMI 531 - AT - Income TaxDetermination of arm's length price - Architectural services - Contention of Assessee was that directions issued by the DRP is not justified in treating the international transactions entered into between Appellant and its Associated Enterprises as sham and concluding the arm's length price as Nil in respect of service charges paid to its Associated Enterprises. Held that:- As the assessee has not filed the requisite information before the DRP due to inadvertence. The requisite information asked for by the DRP has been filed by the assessee belatedly after completion of hearing. Information was filed on 23rd Sept. 2010 though the assessment was completed on 20-9-2010. Consideration of the requisite information filed by the assessee is important to come to a conclusion on the issue in dispute by the DRP - remit the issue back to DRP to consider the same in the light of the evidences - appeal is treated as allowed for statistical purpose.
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