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ALP of corporate management couldn't be taken as AE by taking view that assessee didn't drive any benefit from it

January 2, 2019[2018] 100 taxmann.com 418 (Delhi - Trib.)
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IT/ILT-I: Where in respect of corporate management charges paid to AE, assessee had furnished detailed description of intra group services rendered by AE, copy of ledger account of corporate management charges and allocation chart for earlier assessment year etc., TPO could not determine ALP of said charges at nil by taking a view that assessee did not derive any benefit from payment of said charges

IT/ILT-II: Where assessee was engaged in providing computer aided designing i.e. a kind of business of support services to AE, a company providing full fledged procurement and financial management support services, could not be accepted as comparable

IT/ILT-II: Where assessee was rendering computer aided designing services to AE, a company engaged in providing share registry, record management, fund management and payroll processing services, was not acceptable as comparable

IT/ILT-II: Where assessee was engaged in rendering computer aided designing services to AE, a company providing architect services, could not be accepted as comparable

IT/ILT-II: Where assessee was engaged in providing computer aided designing services to AE, a company involved in trading and receiving commission income as an agent from trading, could not be accepted as comparable

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