Tribunal rules in favor of assessee for assessment years 2013-14 and 2014-15

The tribunal ruled in favor of the assessee for all issues raised in the appeals concerning assessment years 2013-14 and 2014-15. The adjustments related to corporate support services, manufacturing segments, and corporate cost allocation were all decided in favor of the assessee. The tribunal emphasized consistency in decisions across assessment years and highlighted the lack of distinguishing features or contrary orders presented by the Revenue. The appeals were allowed in favor of the assessee, with the tribunal referencing previous cases supporting the assessee's position and upholding the internal TNMM method for determining the arm's length price.

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Issues involved:
1. Assessment years 2013-14 and 2014-15 - TP adjustments for corporate support services.
2. Assessment years 2013-14 and 2014-15 - TP adjustments for manufacturing segments.
3. Assessment years 2013-14 and 2014-15 - Corporate cost allocation disallowance.

Analysis:
Issue 1: Assessment years 2013-14 and 2014-15 - TP adjustments for corporate support services
The appeals arose against assessments framed by the DCIT, Cir-8, Pune, following directions from the Dispute Resolution Panel-3, Mumbai. The main issue was the arm's length price (ALP) adjustment of Rs.13,16,72,743/- for corporate support services received from overseas associate enterprises. The tribunal's co-ordinate benches consistently ruled in favor of the assessee in previous assessment years. The tribunal found no distinction in facts or law presented by the Revenue, leading to a decision in favor of the assessee. The tribunal referred to previous cases where similar issues were decided in favor of the assessee, establishing a pattern of decisions supporting the assessee's position. The tribunal allowed the assessee's appeal concerning this issue.

Issue 2: Assessment years 2013-14 and 2014-15 - TP adjustments for manufacturing segments
The TP adjustments of Rs.6,26,38,000/- and 3,85,97,146/- related to manufacturing segments were also challenged. The tribunal noted errors in the TPO's rejection of the internal TNMM method used by the assessee to determine the ALP of international transactions. The tribunal upheld the internal TNMM method, citing previous cases where this method was deemed appropriate. The tribunal found no contrary orders presented by the Revenue, leading to a decision in favor of the assessee. The tribunal allowed the assessee's appeal regarding this issue.

Issue 3: Assessment years 2013-14 and 2014-15 - Corporate cost allocation disallowance
The disallowance of corporate cost allocation was another issue raised in the appeals. The tribunal, based on consistency in previous decisions and lack of distinguishing features, decided in favor of the assessee. The tribunal adopted judicial consistency and ruled in favor of the assessee against the department. The appeals were allowed in favor of the assessee, and a common order was issued for both appeals. The tribunal emphasized the importance of maintaining consistency in decisions across assessment years.

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