TMI Blog2022 (10) TMI 1056X X X X Extracts X X X X X X X X Extracts X X X X ..... ther ITAT has erred in subjecting the transaction pertaining to receipt of administrative services to comparable uncontrolled price ( CUP ) method without demonstrating any comparable instances and ignoring the arm's length analysis submitted by the Appellant? - HELD THAT:- This Court finds that all the three authorities below have given concurrent findings of fact that the Appellant had faile ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... other assessment year, as it has to be decided based on the evidences produced to establish the claim of receipt of services from AE. Further, this Court in Principal Commissioner of Income Tax-6 vs. Make My Trip India (P) Ltd. [ 2017 (11) TMI 587 - DELHI HIGH COURT ] has held that difference of opinion between the parties, as to the appropriateness of one or the other methods to calculate arm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2022 passed by the Income Tax Appellate Tribunal ( the ITAT ) in ITA No. 6007/Del./2014 for the Assessment Year 2008-09. 2. Learned counsel for the Appellant states that the ITAT has erred in upholding the transfer pricing adjustment amounting to Rs.1,94,65,250/-in respect of the international transaction pertaining to receipt of business support services and the arm s length price of the said ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... gned order .On a specific query made by the Bench to demonstrate the receipt of services from AE through cogent evidence, including, any communication with the AE, learned counsel for the assessee expressed his inability to furnish any evidence and repeated his submission to restore the matter back to the Assessing Officer for enabling the assessee to furnish evidence, if any. . 6. This Co ..... X X X X Extracts X X X X X X X X Extracts X X X X
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