B G EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME, DDIT/ ADIT (INTERNATIONAL TAXATION), CIRCLE-1, DEHRADUN, DEHRADUN, UTTARAKHAND

In the result, both the appeals of the assessee are allowed

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

reopening the case of the assessee for AY 2015-16 are invalid and cannot form the basis for reassessment. Ground No. 2: Erroneous disallowance of payment made towards intra-group services by Appellant to its Associated Enterprise (“AE”) 2.1 The learned Transfer Pricing Officer ("TPO") / AO / DRP grossly erred in law and on facts by making an upward transfer pricing

B G EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME, DDIT/ ADIT (INTERNATIONAL TAXATION), CIRCLE-1, DEHRADUN, DEHRADUN