Wednesday 17 June 2015

TPO couldn't consider ALP of technical service fee as nil without considering break-up of cost incur

IT/ILT : Where TPO made addition to assessee's ALP by taking value of technical service fee paid by assessee to its AE at nil, since in order to prove genuineness of payment in question, assessee had given breakup of costs incurred by parent company and basis of apportionment but same had not been considered at all by TPO, impugned addition was to be set aside and, matter was to be remanded back for disposal afresh

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