ITAT Delhi Deletes SLS Disallowance as APA Covered Intra-Group Services

Ericsson India Pvt. Ltd. Vs JCIT (ITAT Delhi) The appeal before the Income Tax Appellate Tribunal (ITAT), Delhi Bench, arose from the assessment order dated 22.12.2016 passed under Sections 143(3) read with 144C(3) of the Income-tax Act, pursuant to the directions issued by the Dispute Resolution Panel (DRP) under Section 144C(5) for Assessment Year 2012-13. The principal dispute concerned the disallowance of expenditure relating to intra-group “Second Line Support” (SLS) services under Section 37(1) of the Act. The assessee, a wholly owned subsidiary of a Swedish parent company, w...