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2016 (6) TMI 1386 - AT - Income TaxTP Adjustment - TPO attributed 100 percent of the loan syndication fee income to the Appellant and Nil to the AE - assessee submits that in similar type of cases, the Hon’ble Tribunal held that only 20 to 25% loan syndication fee is attributable to the assessee but not 100% as was done by the Assessing Officer - HELD THAT:- As relying on Calyon Bank Vs DDIT [2014 (3) TMI 1158 - ITAT MUMBAI] and M/s. Credit Lyonnais Vs ADIT [2014 (7) TMI 1 - ITAT MUMBAI] we restore this issue to the file of the Assessing Officer to follow the decisions and decide the issue in line with the above decisions for allocation of loan syndication fee between the assessee and its AE after giving opportunity of being heard to the assessee.
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