Assessing Officer's Reliance on Morgan Stanley Deemed Inappropriate in Transfer Pricing Case for Nalco Services.

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....Transfer pricing - international transactions - Determination of the nature of services availed by the assessee - We observe that the rendition of services by Nalco, USA and Nalco Pacific Pte Ltd., Singapore has given effect only to the assessee and has, in no manner, resulted in protecting the individual interests of such companies. All the services rendered by them facilitated the carrying on of the assessee's business. In such circumstances, we are satisfied that the reliance of the AO on the decision in Morgan Stanley [2007 (7) TMI 201 - SUPREME COURT] is misconceived. - AT....