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ITAT upheld CIT(A)'s deletion of transfer pricing adjustment regarding Global Client Management Fee paid by assessee to its Danish associated enterprise. The Tribunal found that ISS World Service A/S Denmark legitimately provided global client management services to assessee for serving large corporate clients in India. ITAT noted consistent findings in assessee's favor for assessment years 2015-16 and 2016-17 where similar ad hoc 50% adjustments by TPO were deleted. Revenue's grounds challenging deletion of TP adjustment were dismissed. However, regarding Section 14A disallowance computation read with Rule 8D, ITAT set aside CIT(A)'s findings and remanded matter to Assessing Officer for fresh consideration after examining assessee's submissions claiming proportionate composite administration expenditure of Rs. 89,783. Revenue's appeal partially allowed for statistical purposes on Section 14A issue while assessee's cross-objection also allowed for statistical purposes.
ITAT upheld CIT(A)'s deletion of transfer pricing adjustment regarding Global Client Management Fee paid by assessee to its Danish associated enterprise. The Tribunal found that ISS World Service A/S Denmark legitimately provided global client management services to assessee for serving large corporate clients in India. ITAT noted consistent findings in assessee's favor for assessment years 2015-16 and 2016-17 where similar ad hoc 50% adjustments by TPO were deleted. Revenue's grounds challenging deletion of TP adjustment were dismissed. However, regarding Section 14A disallowance computation read with Rule 8D, ITAT set aside CIT(A)'s findings and remanded matter to Assessing Officer for fresh consideration after examining assessee's submissions claiming proportionate composite administration expenditure of Rs. 89,783. Revenue's appeal partially allowed for statistical purposes on Section 14A issue while assessee's cross-objection also allowed for statistical purposes.
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