COMPASS INDIA SUPPORT SERVICES PRIVATE LTD. ,GURGAON vs. DCIT, CIRCLE-4(2), DELHI

ITA 1383/DEL/2022Status: DisposedITAT Delhi04 February 2026AY 2018-1937 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the orders of the DRP and TPO, affirming that the benefit test for intra-group services is well-recognized and requires direct, substantial benefits. The assessee's generic explanations and failure to provide documentary evidence were insufficient.

What were the facts?

The assessee, an Indian subsidiary, received allocation of IT software license and support expenses from its foreign Associated Enterprises (AEs). The Transfer Pricing Officer (TPO) held that the assessee failed to substantiate the benefits received and benchmarked the arm's length price at Nil.

What were the issues?

Whether the assessee received tangible benefits from intra-group IT services provided by its AEs, and whether the payments made were at arm's length.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 92CA

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH, H: NEW DELHI

Before: SHRI YOGESH KUMAR US & SHRI BRAJESH KUMAR SINGH

For Appellant: Shri KM Gupta, Adv. &, Ms. Kashish Gupta, CA
For Respondent: Shri S.K. Jadhav, CIT(DR)
Hearing: 11.11.2025Pronounced: 04.02.2026

PER BRAJESH KUMAR SINGH, AM, ITA No.-511/Del/2022 and 1383/Del/2022 Compass India Support Services Pvt. Ltd.

These two appeals have been preferred by the assessee against the Final Assessment Order dated 28.01.2022 and 30.04.2022 respectively, p

The order continues below.

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