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...