Case Law Details
DCIT Vs Knorr Bremse India Pvt. Ltd. (ITAT Delhi)
TNMM is the Most Appropriate Method to benchmark the international transactions entered into by the taxpayer with its AE qua professional consultancy services (information technology) and fee for management support services but TPO, for the reasons best known to him and to our mind to generate unnecessary litigation, proceeded to apply the CUP method by applying same reasoning applied in the earlier years.
So, ld. CIT (A) has rightly deleted the additions by following the orders passed by the Tribunal and Hon’ble Punjab & Haryana High Court (supra) passed in taxpayer’s own case. Consequently, the appeal filed by the Revenue is dismissed.
FULL TEXT OF THE ITAT JUDGEMENT
Appellant, DCIT, Circle 1, Faridabad (hereinafter referred to as ‘the Revenue’) by filing the present appeal sought to set aside the impugned order dated 09.03.2018 passed by the Commissioner of Income-tax (Appeals), Faridabad qua the AY 2014-15 on the grounds inter alia that :-
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