2015 (2) TMI 1084

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.... S. Reddy (Accountant Member) This is an appeal filed by the assessee directed against the order of Assessing Officer passed u/s 143(3) r.w.s. 144C r.w.s. 254 of the Income Tax Act 1961 (hereinafter referred to as the Act). 2. In the first round of appellate proceedings the ITAT, in ITA No. 5730/Del/2011 order dated 5.9.2012 held as follows: "7. A perusal of the above contents of the written s....

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.... assessee before the TPO." 3. The DRP vide its order dated 16.8.2013 in the set aside proceeding at Para 6 & 7 has observed as follows: "6. In view of the above directions of the Hon'ble ITAT, the matter before the DRP is limited to re-appraisal of the data provided by the assessee before the TPO on the issue of availing of intra-group services. 7. Assessee had submitted transfer pricin....

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....PO, DRP comes to the conclusion that the TPO was right in holding that the arm's length price of this transaction relating to receipt of corporate services was nil. " 5. Aggrieved the assessee filed an appeal, it also filed an application for admission of additional evidence as the DRP did not consider the evidence filed before it. . 6. After considering the rival submissions, we are of the....