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2021 (9) TMI 1243 - AT - Income TaxTP Adjustment - payment made for intra group services - CIT(A) directed the TPO to grant 50% of the adjustment claimed by the assessee on account of intra-group services - scope of commercial expediency - HELD THAT:- Since the issue has already been decided by the Tribunal [2020 (2) TMI 1567 - ITAT DELHI]favour of the assessee by deleting 50% of disallowance sustained by the Ld. CIT(A), therefore, in view of the Order of the Tribunal, we do not find any infirmity in the Order of the Ld. CIT(A) in deleting the adjustment on account of payment of intra group service to A.E. Ground Nos. 1 to 3 of the appeal of the Revenue are accordingly dismissed. Reimbursement payment from the operating cost - international transaction relating to provision of management consultancy services provided to AEs and reimbursement of expenses from AEs - HELD THAT:- As decided in own case[2020 (2) TMI 1567 - ITAT DELHI].restored the issue to the file of A.O./TPO with a direction to verify the analysis done by them in subsequent years and find-out as to whether this company is functionally similar or dissimilar to that of the assessee company and decide the issue as per fact and law.
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