TMI Blog2022 (9) TMI 1567X X X X Extracts X X X X X X X X Extracts X X X X ..... THAT:- Admittedly, the issue pertaining to infra group services is covered by the judgement of this Court [ 2016 (9) TMI 244 - DELHI HIGH COURT] in assessee s own case ITAT as agreeing with assessee contention that agreement between the Assessee and its AE was a composite one and could not be split up for the purposes of holding that some services are at arm s length and some are not as on viewin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that during the Financial Year 2008-09, the assessee had net monthly balance payable to the AEs as opposed to monthly balance receivable from the AEs as alleged by the Assessing Officer. Consequently, given the concurrent findings of facts by the Appellate Authorities below that the debtor days given to the AEs are less than the debtor days given to non-AEs, no substantial question of law arises. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... characterized the infra group services transaction, without appreciating that the TPO has not disallowed the infra group services merely on the issue of non-substantiation of commercial expediency by the assessee but on several other factors. 3. He also states that the ITAT has erred in not considering interest on outstanding receivables as an international transaction as per Section 92 (B) read w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the services resulted in any actual benefit to the Assessee or not. 4. Having heard learned counsel for the Revenue at length and having perused the orders of the TPO, CIT(A) and the ITAT, the Court is of the view that the view taken by the ITAT is plausible one and does not warrant any interference. 5. The Appellate Authorities have concluded that facts of present case are similar to the fact ..... X X X X Extracts X X X X X X X X Extracts X X X X
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