9911796707
TMI Blog2019 (7) TMI 1326X X X X Extracts X X X X X X X X Extracts X X X X ..... AT has given detailed reasons for accepting the case put forward by the Assessee. The view taken is a plausible one and does not give rise to any substantial question of law. Other submission made is that the ITAT in fact did not consider the materials placed before the TPO and the decision taken thereon by the TPO in relation to each of the intra group services received by the Assessee from its AEs. The Court finds that the ITAT has in fact applied its mind to the evidence on record and given factual findings which this Court does not find to be perverse. No substantial question of law arises - ITA 662/2019 - - - Dated:- 23-7-2019 - S. MURALIDHAR AND TALWANT SINGH JJ. Appellant Through: Mr. Deepak Anand, Sr. Standing C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r as the ITAT s order for AY 2013-14 is concerned the Assessee came in appeal to this Court by filing ITA No.219 of 2019. While disposing of the Assessee s appeal vide order dated 8th March 2019 this Court clarified that the TPO will pass a fresh order for AY 2013-14 uninfluenced by the observations made by the ITAT for the AY 2012-13. 6. It is accordingly pointed out by learned counsel for the Assessee appearing on advance notice that these two AYs i.e. 2012-13 and 2013-14 stood on a different footing and even there this Court was persuaded to clarify that the facts for one AY i.e. 2012-13 would not influence the decision in the subsequent AYs i.e. 2013-14. 7. Learned counsel for the Revenue made two submissions. One was ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ents have been made in pursuance to written agreements, in our considered opinion, the same should be a reasonable basis to confirm that payments are legitimate. 10. The Court finds that the ITAT has given detailed reasons for accepting the case put forward by the Assessee. The view taken is a plausible one and does not give rise to any substantial question of law. 11. The other submission made is that the ITAT in fact did not consider the materials placed before the TPO and the decision taken thereon by the TPO in relation to each of the intra group services received by the Assessee from its AEs. The Court finds that the ITAT has in fact applied its mind to the evidence on record and given factual findings which this Co ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
