Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2021 (2) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2021 (2) TMI 833 - AT - Income TaxTP Adjustment in respect of Regional Management Charges - TPO concluded that the assessee has failed to provide documents in support of various services availed and determined the Arm's Length Price (ALP) of Regional Management Services at nil, thereby making adjustment - HELD THAT:- Considering the fact that in the impugned assessment year the services were rendered by AE in pursuance to the same Regional Services Agreement dated 23/11/2010 and there has been no change in the nature of services rendered by AE and method of remuneration, we see no reason to take a different view. Therefore, in the facts of the case and the decisions of Co-ordinate Bench in assessee's own case for assessment year 2011-12 and assessment year 2013-14, the transfer pricing adjustment on account of Regional Management Charges paid to foreign A.E is deleted for parity of reasons. To amplify the services rendered the assessee has filed copies of debit notes supporting Regional Management Charges, cost benefit analysis of Regional Management Charges, reasons for availing intra group services, nature of services availed, basis of charges, etc. The ld. Departmental Representative has not disputed that the nature of expenditure in respect of Regional Management Charges in the impugned assessment year is in any manner different from that in the preceding assessment year.[2021 (2) TMI 773 - ITAT MUMBAI].- Appeal by the assessee is allowed.
|