IT/ILT: Matter remanded where in earlier year on similar fact situation, Tribunal directed for fresh TP adjudication
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[2014] 51 taxmann.com 565 (Delhi - Trib.)
IN THE ITAT DELHI BENCH 'I'
VA Tech Escher Wyss Flovel (P.) Ltd.
v.
Deputy Commissioner of Income-tax, Circle-1, Faridabad*
R.S. SYAL, ACCOUNTANT MEMBER
AND GEORGE GEORGE K., JUDICIAL MEMBER
IT APPEAL NO. 1000 (DELHI) OF 2014
[ASSESSMENT YEAR 2009-10]
SEPTEMBER 24, 2014
Section 92C of the Income-tax Act, 1961 - Transfer pricing - Computation of arm's length price (Comparables and adjustment) - Assessment year 2009-10 - Assessee paid a sum as technical fees towards technical services rendered by its AE - TPO being of opinion that any service was not actually availed by assessee, made TP adjustment - Tribunal in earlier year, on same facts, remanded matter to determine ALP of said transaction - Whether therefore, matter needed fresh readjudication - Held, yes [Para 5][In favour of assessee/Matter remanded]
■■■
[2014] 51 taxmann.com 565 (Delhi - Trib.)
IN THE ITAT DELHI BENCH 'I'
VA Tech Escher Wyss Flovel (P.) Ltd.
v.
Deputy Commissioner of Income-tax, Circle-1, Faridabad*
R.S. SYAL, ACCOUNTANT MEMBER
AND GEORGE GEORGE K., JUDICIAL MEMBER
IT APPEAL NO. 1000 (DELHI) OF 2014
[ASSESSMENT YEAR 2009-10]
SEPTEMBER 24, 2014
Section 92C of the Income-tax Act, 1961 - Transfer pricing - Computation of arm's length price (Comparables and adjustment) - Assessment year 2009-10 - Assessee paid a sum as technical fees towards technical services rendered by its AE - TPO being of opinion that any service was not actually availed by assessee, made TP adjustment - Tribunal in earlier year, on same facts, remanded matter to determine ALP of said transaction - Whether therefore, matter needed fresh readjudication - Held, yes [Para 5][In favour of assessee/Matter remanded]
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