TP Adjustment: Payment made for management related activities under CSA- ITAT remanded the issue back to AO

Atotech India Pvt. Ltd. Vs DCIT (ITAT Delhi)

TP Adjustment: Payment made for management related activities under CSA- ITAT remanded the issue back to AO

We find that the only controversy involved in all the assessee’s appeals is with regard to payment made for management related activities under CSA which has been taken at ‘Nil’ by the TPO. This adjustment is a recurring issue in assessee’s own case right from the Assessment Years 2007-08, 2009-10 and Assessment Year 2012-13. The Tribunal has remanded this issue to the file of the Assessi

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