No second innings should be given to appreciate same set of facts: ITAT

ACIT Vs Volvo Auto (India) Private Limited (ITAT Delhi) The issue under consideration is whether CIT(A)is correct in deleting the addition made on application of CUP method for determination of ALP of international transactions by the A.O.? ITAT states that, the AO’s observation that this expenditure has been debited to the profit and loss account to inflate the expenses and thereby reduce the taxable profits in India is not borne out from the facts on record. Further, the claim of management service fee paid by the appellant to its AE has also been examined in the 2 subsequent years and the...