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2023 (6) TMI 1367 - ITAT DELHITP Adjustment - evidence of intra-group services furnished by the assessee - direct nexus between the revenue earned/ cost incurred by the Assessee and the majority intra-group services received obtained or not? - HELD THAT:- We note that the assessee has furnished enormous evidences which point out that intra group services have in fact been received by the assessee. Moreover, the agreement is a composite one and authorities below have allowed part of the same and treated part of the same not allowable. On similar facts, ITAT has deleted the adjustment for several years and the Revenue’s appeal against them has been dismissed by Hon’ble High Court. We find that the above order applies on all fours to the present appeals. Here also from the composite agreement, some have been accepted at arm’s length price and some have been treated as not acceptable at arm’s length price. Huge details of intra-group services have been furnished by the assessee. Respectfully following the precedent from the ITAT and Hon’ble High Court, we uphold the contention of the assessee and delete the TP adjustment.
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