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2022 (3) TMI 1471 - AT - Income TaxTP Adjustment - Arm’s Length Price adjustment for availing of corporate management service from the associated enterprises of the assessee - As argued assessee had produced all the documents to prove that the assessee had availed services from its AE’s, but the authorities below have not considered the materials available on record - HELD THAT:- In view of the above discussions and the orders of the Tribunal, we are incline to remit this issue in dispute to the file of AO/TPO to decide afresh after considering the documents submitted by the Assessee. It is needless to say that, it is the duty of the Assessee to prove that there was actual rendering of the services by AE’s to the assessee and the payment has been made to the AE’s itself for such services. The said issue shall be decided by the AO/TPO, after providing adequate opportunity to the assessee. Accordingly, the Grounds No. 1 to 1.4 are allowed for statistical purpose.
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