2021 (9) TMI 1361

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....e Revenue is directed against the order passed by the CIT(A) on 08-02-2017 in relation to the assessment year 2010-11. 2. The only ground effective raised by the Revenue in the appeal is as under : "On the facts and circumstances of the case, the CIT(A) has erred in holding that intra groups activities performed by Nalco US under SA and by Nalco Pacific under the RMASA constitute intra group se....

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.... availed by the assessee were in the nature of stewardship activity and not intra group services. This is how, he determined Nil ALP of the international transactions and proposed transfer pricing adjustment of Rs. 17,21,93,000/-. The AO made such an addition. The ld. CIT(A) deleted the addition by holding that the services availed by the assessee were in the nature of intra group services and not....

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....preceding year, both the sides made elaborate submissions. In fact, the parties adopted their submissions made for the earlier year insofar as the instant appeal is concerned. This shows that the nature of services availed by the assessee from Nalco, USA and Nalco Pacific Pte Ltd., Singapore is similar to that of the preceding assessment year. We have passed separate order for the assessment year ....