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2018 (5) TMI 2144 - AT - Income TaxTP Adjustment - determination of arm's length price by TPO/AO for management services received by the Appellant - TPO observed that the entire services are stewardship in nature and received by the Associate Enterprises for maintenance of overall control of the group - HELD THAT:- This issue is squarely covered in favour of the assessee by the decision of the Coordinate Bench in assessee’s own case and there is no change in facts and law and the Revenue is unable to produce any material to controvert the aforesaid findings. Therefore, we are of the view that arm’s length price adjustment made by the DRP/Assessing Officer in respect of management services needs to be deleted. Accordingly, we delete the arm’s length price adjustment in relation to management services - Appeal filed by the assessee, is allowed.
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