MICHAEL PAGE INTERNATIONAL RECRUITMENT PVT LTD,MUMBAI vs. DCIT CIRCLE 14(1)(1), MUMBAI

ITA 6748/MUM/2024Status: DisposedITAT Mumbai16 October 2025AY 2021-2223 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal found that the assessee had provided sufficient evidence to demonstrate that services were rendered and that some benefit accrued. The Tribunal noted that a similar approach by the TPO/DRP in a previous assessment year was rejected by the Tribunal.

What were the facts?

The assessee, an Indian subsidiary of Michael Page Group, paid its Associated Enterprises (AEs) for business support and technology services. The Transfer Pricing Officer (TPO) rejected the assessee's transfer pricing documentation and determined the Arm's Length Price (ALP) to be Nil, disallowing the entire payment.

What were the issues?

Whether the transfer pricing adjustment made by the TPO, determining the ALP of intra-group services as Nil, is justified. Whether the disallowance of intra-group service charges under Section 37 is valid.

Which sections of the Income-tax Act were involved?

Section 92C,Section 92D,Section 143(3),Section 144B,Section 144C,Section 37,Section 41,Section 153

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “J” BENCH, MUMBAI

Per Rahul Chaudhary, Judicial Member:

1.

The present appeal is directed against the Final Assessment Order, dated 23/10/2024, passed under Section 143(3) read with Section 144C(13) read with Section 144B of the Income Tax Act, 1961 [hereinafter referred to as 'the Act'], as per directions, dated 25/09/2024, issued by the Commissioner of Income Tax (Dispute Resolution Panel-3), Mumbai 3 (hereinafter referred to as 'the DRP') under Section 144C(5) o

The order continues below.

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