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2020 (9) TMI 1298 - AT - Income TaxTP Adjustment - MAM - HELD THAT:- We find, the tribunal in M/S TOWER WATSON INDIA PVT LTD VERSUS THE DY. C.I.T GURGAON [2019 (5) TMI 327 - ITAT DELHI] has thoroughly discussed the issue in question and held that CUP is the most appropriate method in the instant case. Since the facts of the instant case are identical to the facts for the A.Y. 2011- 12, therefore, respectfully following the decision of the Tribunal in assessee’s own case and in absence of any distinguishable features brought to our notice, we are of the opinion that CUP is the most appropriate method in the instant case which has been applied by the assessee for benchmarking the transactions for provision of consultancy services rendered. We hold and direct accordingly. Since the ground of appeal No.2 is decided in favour of the assessee. Denial of TDS credit - HELD THAT:- We, therefore, deem it proper to restore this issue to the file of the AO with a direction to verify the record and give proper credit of the TDS - AO shall give due opportunity of being heard to the assessee and decide the issue as per fact and law. Ground raised by the assessee is allowed for statistical purposes.
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