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2021 (1) TMI 410 - AT - Income TaxTP Adjustment - ALP adjustment made to group service fees paid by the assessee to its Associate Enterprises (AEs) - HELD THAT:- The Tribunal in assessee’s own case for assessment year 2012-2013 had directed to do afresh transfer pricing analysis and determine the ALP of international transactions with regard to group service fees paid by the assessee to its AEs. AO / TPO shall follow the same directions that are given by the ITAT in assessee’s own case for assessment year 2012- 2013 for determining the ALP of impugned international transaction the assessee had with its AE’s.. Appeal filed by the assessee is allowed for statistical purposes.
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