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2023 (1) TMI 1113 - AT - Income TaxTP Adjustment - payments to its overseas associate enterprise “AE” in lieu of “Receipt of Advisory Services” - HELD THAT:- The assessee’s service agreement has remained the same throughout since 2003 onwards - We therefore conclude in this factual backdrop that the assessee has sufficiently proved to have received “advisory services” from its group entity(ies) and the learned lower authorities have erred in law and on facts in rejecting the same in entirety. We, accordingly, delete the impugned adjustment in these peculiar facts and circumstances. The assessee succeeds in its first and foremost grievance.
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