Disallowance of rebate/discount to its overseas AEs: ITAT directs AO to verify Agreements/MOUs

Bureau Veritas Consumer Products Services (India) Private Limited  Vs ACIT (ITAT Delhi) ITAT held that It is true that the assessee has paid rebate/discount to its overseas AEs. It is equally true that such arrangement has been done through Master Service Agreements (‘MSA’) with various overseas companies (sample JC Penny ) for providing testing and inspection services. Under such MSA, BV overseas entities have agreed to provide for a volume rebate and discount at a pre-decided percentage to the overseas customers in relation to worldwide sale of services made to the entire group ...