2019 (7) TMI 1326

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.... Respondent Through: Mr. Vishal Kalra, Advocate. O R D E R CM APPL. 32141/2019 (delay) in ITA 662/2019 1. For the reasons explained in the application, the delay in filing the appeal is condoned and the application is allowed. ITA 662/2019 2. This is the Revenue appeal against the order dated 29th October 2018 passed by the Income Tax Appellate Tribunal ('ITAT') in ITA No.5404/Del/2....

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....are stated to be pending in the Supreme Court. 5. However, for AYs 2012-13 and 2013-14 the ITAT appears to have remanded the matter to the TPO for a fresh determination. As far as the ITAT's order for AY 2013-14 is concerned the Assessee came in appeal to this Court by filing ITA No.219 of 2019. While disposing of the Assessee's appeal vide order dated 8th March 2019 this Court clarified that t....

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....asons for not remanding the issue to the TPO. In particular, the ITAT noted that in AYs 2010-11 to 2012-13 the Dispute Resolution Panel ('DRP') accepted the Assessee's determination of the ALP with regard to two intra group services received by the Assessee viz., Ticketing HUB and VIPFS. As regards the other intra group services, the ALP was ascertained to be NIL by application of the CUP. 9. T....

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....ayments have been made in pursuance to written agreements, in our considered opinion, the same should be a reasonable basis to confirm that payments are legitimate." 10. The Court finds that the ITAT has given detailed reasons for accepting the case put forward by the Assessee. The view taken is a plausible one and does not give rise to any substantial question of law. 11. The other submissi....