TMI Blog2022 (2) TMI 1301X X X X Extracts X X X X X X X X Extracts X X X X ..... mmunication with the AE, Assessee expressed his inability to furnish any evidence and repeated his submission to restore the matter back to the AO for enabling the assessee to furnish evidence, if any. We are unable to accept the aforesaid submission of learned counsel for the assessee. When the assessee has failed to furnish any evidence either before the departmental authorities or before us to demonstrate that administrative services, indeed, were rendered by the AE and the nature and scope of such services, in our view, no useful purpose would be served in restoring the matter back to the Assessing officer for reconsidering the issue. In view of the aforesaid, we do not find any valid reason to interfere with the decision of Commissione ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... T (Appeals) erred in considering the payment of INR 19,465,250 by the Appellant towards the administrative services received from the Associated Enterprises ( AEs ) to be Nil , and in doing so grossly erred in law and in facts for the following reasons: 3.1. applying the Comparable Uncontrolled Price method and rejecting the application of Transactional Net Margin Method as most appropriate method for determination of arm s length price in case of payment of administration fee. 3.2. drawing conclusion as regards to no economic value was derived and that no tangible and substantial commercial benefit was derived out of services for which the admin fee was paid. 3.3. disregarding the collective evidences provided in justification of the arm s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ished its reply stating therein that it has entered into a service agreement with another group company, viz., Akzo Noble Car Refinishes, Singapore, wherein Akzo Noble Car Refinishes has provided administrative support services in the nature of supply chain management support, marketing commercial services support, commercial vehicle support, automotive aftermarket support, supporting R D, human resources, finance management and general management support. 5. In the submissions so made, the assessee further elaborated the nature of services provided by the AE. After analyzing the submissions of the assessee qua the facts and materials on record, the TPO held that the assessee was unable to file any evidence to demonstrate that any such serv ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he submitted, the matter may be restored back to the Assessing Officer for providing opportunity to the assessee to furnish more evidence to demonstrate that the services, indeed, were received. 7. Strongly relying upon the observations of the departmental authorities, learned Departmental Representative submitted that the assessee did not furnish any evidence to demonstrate services, indeed, were received. Therefore, there is no reason to interfere with the decision of the departmental authorities. 8. We have considered rival submissions and perused the materials on record. Undisputedly, the issue in dispute is with regard to determination of ALP of certain intra-group services claimed to have been received by the assessee from its AE. It ..... X X X X Extracts X X X X X X X X Extracts X X X X
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