Group service fees paid to AEs: ITAT restore the matter to AO / TPO

Disa India Limited Vs ITO (ITAT Bangalore)

The Tribunal in assessee’s own case for assessment year 2012-2013 (supra) had directed to do afresh transfer pricing analysis and determine the ALP of international transactions with regard to group service fees paid by the assessee to its AEs.

In view of the Tribunal order in assessee’s own case for assessment year 2012-2013 (supra), which is identical to the facts of the instant case, we restore the matter to the AO / TPO. The AO / TPO shall follow the same directions that are given by the ITAT in assessee’s own case for assessment year 2012­-2013 for determining the ALP of impugned international transaction the assessee had with its AE’s.

FULL TEXT OF THE ITAT JUDGEMENT

This appeal at the instance of the assessee is directed against the final assessment order dated 21.09.2017 passed u/s 143(3) r.w.s. 144C(13) of the I.T.Act. The relevant assessment year is 2013-2014.

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