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2021 (2) TMI 1009 - AT - Income TaxTP Adjustment - adjustment made in respect of availing of Management Services - HELD THAT: - In similar circumstances on identical facts this Tribunal in assessee’s own case for A.Y. 2009-10 [2019 (9) TMI 1313 - ITAT PUNE] reversed the order of DRP and directed the AO to accept the value of management services as claimed by the assessee. Similarly, this Tribunal in A.Y. 2010-11 [2020 (2) TMI 114 - ITAT PUNE] also taking into consideration the findings of Tribunal in A.Y. 2009-10 allowed ground No. 3 raised therein and directed the AO to accept the value of management services as claimed by the assessee by reversing the order of DRP Comparability - In the light of the findings of this Tribunal in assessee’s own case for A.Y. 2010-11 for exclusion of Asian Business Exhibition & Conference Ltd. [2020 (2) TMI 114 - ITAT PUNE]by placing reliance on similar issue on same identical facts involved in the case of M/s. John Deere India Pvt. Ltd. [2019 (5) TMI 97 - ITAT PUNE] the order of CIT(A) is upheld and direct the Assessing Officer to exclude the Asian Business Exhibition & Conference Ltd. from the list of comparables. Addition made on account of payment of royalty - HELD THAT:- This Tribunal in assessee’s own case in A.Y. 2010-11 examined the details of payment of royalty on total sales made to Renishaw group entities in detail and held the payment of royalty @ 2% is in accordance with the agreement dated 01-04-2006 which is being renewed from time to time since then involving the year under consideration also and directed the Assessing Officer to accept the arm’s length price adopted by the assessee.. In view of the above as there was no order contrary to the view taken by this Tribunal brought on record by the Revenue, we direct the Assessing Officer to accept the ALP computed by the assessee by adopting TNMM on account of payment of royalty.
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