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2018 (12) TMI 1985 - AT - Income TaxTP Adjustment - international transaction pertaining to availing support and management services by the Appellant from its Associated Enterprise (“AE”) - HELD THAT:- It is noticed that a similar issue having identical facts was a subject matter of the assessee’s appeals for the preceding assessment years 2012-13 and 2013-14 [2018 (8) TMI 126 - ITAT DELHI] respectively wherein the matter has been restored to the file of the TPO wherein TPO is directed to decide the issue afresh after considering the detailed submissions/documentary evidences furnished by the assessee. Assessee is directed to furnish the details of services utilised by it for which it has made the payments to its AEs. Assessee is further directed to demonstrate what benefits it has received from its AEs. TPO is directed to consider the same and decide the issue afresh after giving reasonable opportunity of being heard to the assessee. Appeal of the assessee is allowed for statistical purposes.
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