2025 (11) TMI 752

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....Niraj Sheth, a/w Adv. Jitendra Singh, Adv. Shivali Mhatre,. P.C.:- 1. Heard learned counsel for the parties. 2. Mr. Gupta proposes the following substantial questions of law in support of this appeal raised therein. "(a) Whether in the facts and circumstances of the case and in law, the Tribunal is justified in deleting the Transfer Pricing adjustment pertaining to payment for ad....

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....ot meet the Organisation for Economic Co-operation and Development (OECD) Guidelines of containing safeguards against the manipulation and following sound accounting principles?" 3. Mr. Gupta submits that in this case, the Tribunal, based only upon some emails exchanged between the parties, concluded that advisory services were rendered by the associated enterprise i.e. Groupo Antolin Iriusa, S....

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.... effect. He, however, maintains that issue raised is a pure issue of fact and the Tribunal, based upon overwhelming documentary evidence on record, has concluded that services were rendered by AE and availed by the assessee. Accordingly, he submits that these appeals involve no question of law, much less substantial questions of law. 6. We have considered the rival contentions and perused the r....

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....his line of activity. 8. Even the Transfer Pricing Officer (TPO) has, in his order, referred to the nature of advisory services. The Revenue, however, urged that the services rendered were different from those specified in the agreement. On such basis, the TPO did not allow the deductions. 9. However, we note that the Tribunal, which is a final fact-finding authority, found that there was no....