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2024 (3) TMI 373 - AT - Income TaxTP Adjustment - international transaction of receipt of intra-group services with its Associated Enterprises ("AEs") - Analysis of the documents /evidence furnished with regard to services rendered - HELD THAT:- We find that the issues involved in the appeal before us have been squarely covered in the assessee's own case for the past eight years. The orders of the Tribunal in the case of the assessee for assessment year 2007-10 to 2012-13 and for assessment year 2014-15 to 2016-17 have been perused [2016 (1) TMI 933 - ITAT DELHI], [2015 (12) TMI 1620 - ITAT DELHI], [2016 (9) TMI 1334 - ITAT DELHI], [2018 (10) TMI 1504 - ITAT DELHI], [2018 (6) TMI 1501 - ITAT DELHI], [2017 (7) TMI 1040 - ITAT DELHI] as held it is not the case of no evidence, on the contrary, it is a case where voluminous evidences are being brushed aside holding that no evidence has been filed or are general in nature without appreciating that the services are integral part of the business carried on by the Appellant and it could not have been carried out business in India without the help of these services. - The Hon'ble Supreme Court has also dismissed the Special Leave Petition (Civil) filed by the Revenue [2023 (8) TMI 1439 - SC ORDER] for assessment year 2009-10. In view of the factual contents and the decision of the Hon'ble Supreme Court in the SLP filed by the Revenue (supra), the appeal of the assessee is hereby allowed.
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