Third party cost incurred is CUP for reimbursement of expenses to AE

DCIT Vs Transocean Drilling Services (I) Pvt Ltd (ITAT Mumbai) ITAT Mumbai held that when the transaction is in the reimbursement of expenses to AE, the third party cost incurred is a Comparable Uncontrolled Price (CUP) for the reimbursement. Accordingly, adjustment proposed is directed to be deleted. Facts- The assessee company is engaged in the business of coordination / liaisoning services to the group companies. During the year under consideration, the assessee company has shown revenue from operations at Rs.6,54,08,130/- and other related income at Rs.29,78,840/-. AO found that the assess...