2016 (9) TMI 244

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..... ge in these appeals by the Revenue is to an order dated 4th December 2015 passed by the Income Tax Appellate Tribunal ('ITAT') in ITA Nos. 4869 & 4934/Del/2014 for the Assessment Year ('AY') 2008-09, and ITA Nos. 4868 & 4933/Del/2014 for AY 2007-08. 2. The question urged by the Revenue concerns the determination of the Arms Length Price ('ALP') by the Transfer Pricing Officer ('TPO') of the inter .....

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..... the Assessee on viewing the agreement as a whole. It was not within the purview of the TPO to determine if some of the services resulted in any actual benefit to the Assessee or not. 4. Having heard learned counsel for the Revenue at length and having perused the orders of the TPO, CIT(A) and the ITAT, the Court is of the view that the view taken by the ITAT is plausible one and does not warrant .....

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