M/S CENTRIENT PHARMACEUTICALS INDIA PRIVATE LIMITED,NAWANSHAHAR vs. ADDITINAL/JOINT/DEPUTY/ASSTT. C.IT,ITO,NEAC, DELHI
In the result, appeal of the assessee is partly allowed for statistical purposes
ITA 102/CHANDI/2021[2016-17]Status: DisposedITAT Chandigarh18 Jun 2024AY 2016-17
Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)
For Appellant: Shri Darpan Kirpalani, AdvocateFor Respondent: Shri Rohit Sharma, CIT DR
Section 144
method and determined ALP of the transaction as Nil. The TPO has further observed that no independent party would have made a similar payment in uncontrolled circumstances. We find that this issue is perennial in nature, the TPO has been consistently making TP adjustment in respect of corporate services fee for similar reasons. The co-ordinate bench in appeal
