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2018 (10) TMI 1994 - AT - Income TaxTP Adjustment - ALP determination - export of finished goods by the appellant to its parent company for further sale to independent customers at same prices - HELD THAT:- As the issue is squarely covered in favour of the assessee by the decision of the Coordinate Bench in assessee’s own case [2018 (5) TMI 900 - ITAT KOLKATA] and there is no change in facts and law and the Revenue is unable to produce any material to controvert the aforesaid findings of the Division Bench, in assessee`s own case (supra). Respectfully following the above binding precedent, we uphold the contention of the assessee and we delete the ALP adjustment made by ld TPO/AO. Arm’s length price adjustment made in respect of payment of Information Technology (IT Service Cost) and payment of technical support service cost - HELD THAT:- This Tribunal in assessee’s own case [2018 (5) TMI 900 - ITAT KOLKATA] we uphold the contention of the assessee and we delete the ALP adjustment made in respect of payment of Information Technology (IT Service Cost), and arm’s length price adjustment made in respect of payment of technical support service cost. Assessee appeal allowed.
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