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2020 (11) TMI 1091 - AT - Income TaxTP Adjustment - payment made for management related activities under CSA which has been taken at ‘Nil’ by the TPO - HELD THAT:- This adjustment is a recurring issue in assessee’s own case right from the Assessment Years 2007-08, 2009-10 and Assessment Year 2012-13 [2018 (5) TMI 848 - ITAT DELHI]. The Tribunal has remanded this issue to the file of the Assessing Officer with certain directions. Thus, in the same lines, we direct the TPO to carry out fresh analysis and determine the Arm’s Length Price and the payments relating to other R&D task and decide the issue fresh in accordance with law. Appeals of the assessee are allowed for statistical purposes.
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