CORPORATE WORLDWISE STAY LLP,MUMBAI vs. ACIT CIRCLE -20(1), MUMBAI

ITA 5940/MUM/2024Status: DisposedITAT Mumbai06 January 2026AY 2020-21Bench: SHRI VIKRAM SINGH YADAV (Accountant Member), SHRI ANIKESH BANERJEE (Judicial Member)1 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the characterization of transactions, the FAR profile, and the selection of the Profit Split Method were not conclusively examined. Therefore, the matter was restored to the Assessing Officer/Transfer Pricing Officer for de novo adjudication.

What were the facts?

The assessee, a limited liability partnership, provides tour booking services and works with an associated enterprise in Mauritius. The tax authorities treated reimbursements from the associated enterprise as an international transaction and made an upward adjustment, which was partly confirmed by the DRP.

What were the issues?

Whether reimbursements from an associated enterprise constitute an international transaction, and the appropriateness of the Profit Split Method for determining arm's length price.

Which sections of the Income-tax Act were involved?

Section 92,Section 92B,Section 92CA,Section 270A

AI-generated summary — verify with the full judgment below

Before: SHRI VIKRAM SINGH YADAV & SHRI ANIKESH BANERJEE

Hearing: 05/12/2025

Per: Shri Anikesh Banerjee, JM: The instant appeal of the assessee filed against the order of the Assessment Unit, Income-tax Department [in short, Ld.AO’) passed under section 143(3) read with section 144C(13) read with section 144B of the Income-tax Act, 1961 (in short, ‘the Act’), date of order 19/09/2024. The impugned order was originated from the recommendation of the Ld. CIT (DRP)- 1, Mumbai, passed u/s 144C(5) of the Act, date of order 16/09/2024. 2 Corporate Worldwide Stay LLP

2.

The assessee has taken the following grounds:- “GROUNDS OF APPEAL

1.

Objection agai

The order continues below.

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