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2023 (6) TMI 206 - AT - Income TaxTP adjustment - IT and Management Support Charges - HELD THAT:- Tribunal in assessee’s own case for AY 2014-15 [2022 (3) TMI 1528 - ITAT BANGALORE] had restored an identical issue to the TPO to determine the ALP of the IT and Management support charges. Payment of IT support services and management support services are pertaining to the agreement and is binding for AY 2014-15 and also for the relevant assessment year. Restore this issue to the file of the TPO so that consistency can be maintained. TPO is directed to examine the issue afresh by taking into account the evidences filed by the assessee in support of its contention that it was in receipt of services from it AEs for making the above said IT and management support services payments. Ground allowed for statistical purposes.
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