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2021 (2) TMI 1332 - AT - Income TaxTP adjustment - international transaction of provision of sales and marketing support services by the Appellant to its associated enterprise (“AE”) - difference between the current assessment year and the subsequent Assessment Years in which the Revenue has accepted the profile of the assessee - HELD THAT:- It can be seen that the company profile has remained intact to that of sales and marketing support services in nature of coordination support and the assessee company is not into advertisement and marketing agency. These aspects were not properly taken cognizance by the TPO/AO and hence the matter is required to be remanded back to the file of the TPO/AO. All the other issues have to be decided once the issue of recharacterization has been determined by the TPO/AO. Therefore, we are remanding back all the issues to the file of the TPO/AO - Assessee be given opportunity of hearing by following principles of natural justice. Hence, appeal of the assessee is partly allowed for statistical purpose.
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