TP assessment by TPO proceeded on incorrect appreciation of nature of service hence matter restored back

Shell Energy India Pvt. Ltd. Vs DCIT (ITAT Ahmedabad) ITAT Ahmedabad held that the TP assessment carried out by the TPO proceeded on the basis of incorrect appreciation of nature of services availed by the assessee from its AE. Thus, issue of determination of ALP of transactions with AE restored back to TPO. Facts- Vide the present appeal, the appellant has specific challenge to the transfer pricing adjustment made to the international transaction .The services received being in relation to operation of LNG storage and re-gasification terminal of the assessee. The amount of adjustment made by ...