TP – ALP: Every Assessment Year is A Separate Unit, governed by its own peculiar facts

Akzonobel India Private Limited Vs Additional Commissioner of Income Tax (Delhi High Court) Appellant submitted that ITAT has erred in subjecting the transaction pertaining to receipt of administrative services to comparable uncontrolled price (‘CUP’) method without demonstrating any comparable instances and ignoring the arm’s length analysis submitted by the Appellant. He also states that similar administrative services have been provided in the subsequent assessment years and have been accepted by the ITAT. Upon a perusal of the paper book, this Court finds that all the three autho...