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2025 (12) TMI 1496
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....ble Dispute Resolution Panel ('DRP') erred in making an adjustment of Rs. 5,52,62,002 (with respect to payment of management charges) under Chapter X of the Income-tax Act, 1961 ('the Act') under other provisions of the Act. Legal 2. On the facts and the circumstances of the case and in law, the AO has erred in issuing the final assessment order dated 22nd July 2024, beyond the time-limit as prescribed under section 153 of the Act. The final assessment order is, thus, time-barred, and liable to be quashed. 3. On facts and in the circumstances of the case and in law, the learned TPO, the AO and the Hon'ble DRP have erred in not applying one of the prescribed methods as mandated by section 92C(1) of the Act. Accordingly. the order of the TPO dated 28 July 2023 is bad in law and deserves to be quashed. 4. The Id. AO, without appreciating the fact that the erstwhile Appellant viz. Analytics Quotient India Private Limited (PAN AAHCA2860J) was merged into Kantar Analytics India Private Limited, formerly known as Firefly Market Research India Private Limited (PAN: AABCS3498L) vide National Company Law Tribunal (NCLT) order dated 4 Oc....
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....ty proceedings u/s 270A of the Act. The Appellant prays that the additions made by the learned AO/TPO and upheld by the learned DRP be deleted and consequential relief be granted. The Appellant craves leave to add, alter, amend and/ or withdraw any of the above grounds of appeal and to submit such statements, documents and papers as may be considered necessary either at or before the hearing of this appeal as per law" 2. The Ld.AR submitted that a assessee wide application dated 14/04/2025 raised following additional ground: ""11. Assessment Order not issued by National Faceless Assessment Centre in violation of the provisions of law and the CBDT circular 11.1 On the facts and circumstances of the case and in law, the Jurisdictional Assessing Officer ('AO")-Assistant Commissioner of Income Tax 1(3)(1), Mumbai has erred in passing the final assessment order dated 22 July 2024 without having any jurisdiction to pass the same. Accordingly, the said final assessment order is bad in law and deserves to be quashed. 12. Disallowance of Management consultancy services under Section 37 12.1 On facts and in the circumstances of the....
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....rmal Power Co. Ltd. Vs. CIT reported in (1998) 229 ITR 383 and Jute Corporation of India Ltd. Vs. CIT reported in 187 ITR 688, we are admitting additional grounds raised by the assessee. Accordingly, the application dated 14/04/2025 filed by assessee stand allowed. Brief facts of the case are as under: 3. The assessee was formerly known as Firefly Market Research India Pvt. Ltd. prior to that, assessee was known as Analytics Quotient Services India Pvt. Ltd. 3.1 During the year under consideration, the assessee filed return of income on 11/02/2021 declaring total income of Rs. 21,09,48,186/- under the head income from business and Rs. 3,14,14,990/- effort as income from other sources. The case of selected for scrutiny under CASS for verification of following issues: I. Imports II. International related party transaction and services III. Loss from currency fluctuations IV Refund claim V. ICDS compliance and adjustments VI Foreign outward remittance 3.2 The Ld.AO noted that the assessee offers data monitoring, ad hoc consulting, statistical modelling, tools, scorecards, dashboards, customer relationship management,....
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....d into an agreement with its overseas AE i.e. Kantar UK for availing of management consultancy services. As per the terms of the agreement, the AE provides the following services to AQ India: Receipt of management consultancy services which includes, but are not limited to: * Client engagement and client account related support including client co-coordination for various multinational select clients; * General client and business generation support; * Product maintenance, management and operational-related support; * Marketing and business development; * Finance, human resource and other personnel administration support; * Real estate and office administration support; * Research & Development and IT support During the year under consideration, AQ has paid an amount of INR 55,262,002/- to Kantar UK towards availing the aforesaid management consultancy services. 7.2 Cost Components The total costs for the services provided are included in the cost base, which essentially includes the direct and indirect costs incurred, including costs incurred by third parties. Such costs may....
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....omplex functional analysis (OECD Guidelines, Para 3.18). The tested party is the participant in the controlled transaction whose profit attributable to the controlled transaction can be verified using the most reliable data and requiring the fewest and most reliable adjustments. In most cases, the tested party is the least complex of the controlled taxpayers, that is, the taxpayer with the least amount of risk associated with its operations and without valuable intangibles or unique assets. Based on the above analysis, the overseas AE, i.e. Kantar UK have been ascertained as the tested parties for the purpose of determining the appropriateness of 5 and 10 percent mark-up. Selection of the Most Appropriate Method As per the Indian transfer pricing provisions, the income arising from an international transaction with AEs must be computed having regard to the arm's length price. The calculation of the arm's length price has to be done by using the most appropriate method. The most appropriate method must be selected from the following methods: * CUP Method; * RPM; * CPM; * PSM; * TNMM; or ....
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....the relevant cost". Further, the Central Board of Direct Taxes vide notification (CBDT Notification No. 46/2017/F. No. 370142/6/2017-TPL) dated 07 June 2017, revised the safe harbour rules in India. Under rule 10TA of the Income Tax Rules, the definition of LVIGS in clause (ga) is as follows: "low value-adding intra-group services" means services that are performed by one or more members of a multinational enterprise group on behalf of one or more other members of the same multinational enterprise group and which,- (i) are in the nature of support services; (ii) are not part of the core business of the multinational enterprise group, i.e., such services neither constitute the profit-earning activities nor contribute to the economically significant activities of the multinational enterprise group; (iii) are not in the nature of shareholder services or duplicate services; (iv) neither require the use of unique and valuable intangibles nor lead to the creation of unique and valuable intangibles; (v) neither involve the assumption or control of significant risk by the service provider nor give rise to the creation of signif....
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....cial results of a company have been not uploaded to Orbis, 2016 was determined to be the most recent year. * The range of net cost plus mark-ups resulting from this search is: Table 7: Range of NCP mark-up - Kantar UK 35th percentile Medina 65th percentile 4.80% 8.40% 15.10% * The number of companies included in this sample was 101. Conclusion Considering the fact that the management of the company is of the view of the same and having regard to the economic and commercial factors, the mark-up of 5 percent and 10 percent, as falls within the arm's length range. Hence the transaction between AQ India and its AEs can be considered to be at arm's length from an Indian transfer pricing perspective. 3.7 The assessee in TPSR also undertook corroborative analysis of the international transaction of payment for management consultancy services by considering transactional net margin method(TNMM)as the most appropriate method(MAM) and aggregating the transaction with the other international transactions like: * provision of marketing data analytical services * payment for services availed * r....
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.... With regard to the said transaction the assessee submitted that the said services relate to the main business service of the assessee. Further, the assessee provided the Service agreement as entered with Analytics Quotient Inc, USA. Further, the assessee has incorporated the TNMM to benchmark the said transaction. The assessee also stated that these services availed from AE are not in the nature of shared/ common services but pertain to the core business. 2. Management Consultancy Services paid to Kantar UK Limited With regard to the said transaction the assessee submitted that the said services are of the nature of 'support services" for which the assessee has entered into an agreement with Kantar UK Ltd. Further the assessee has incorporated the Other Method to benchmark the said transaction. The assessee specified that the assessee adopts a cost allocation methodology with its AE In the said cost sharing methodology the global group relies on cost minimization theory based on which it centralizes the administrative and managerial support functions. Apart from the above, the assessee submitted that as per section 92C(2) of the Act. ALP has to be applie....
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....not apply in the present case for the reason that Ld. DRP and Ld. TPO have given finding to the effect that how the benefit test will be applicable. Though, the Ld. TPO in A. Y 2010-11 accepted the arm's length nature of the international transactions in PPC and RCS Divisions during the TP assessment for AY 2010-11 as the Ld. TPO has accepted the margins eamed by the assessee company in the PPC and RCS division after including the IGS cost, to be at arm's length, the same can not be accepted in toto, in the present year. The Commissioner of Income Tax (Appeals) in the assessee's case for AY 2008-09, has accepted the arm's length nature of certain services primarily in the nature of "Bid Govemance", "Taxation", "Marketing". "Operations" and "Procurement". But in the present assessment year, there is clear finding by Ld. TPO and Ld. DRP that assessee has not given the details of the total costs incurred by the AE on a particular services. In fact, assessee could not establish how the said cost was incurred and on what basis the said cost was placed upon the assessee The E-mails etc. were also not supported by any documentary evidences. Thus, the assessee's content....
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....ord, it is held that that the assessee has failed to adequately demonstrate that it has received services or that it benefited from such services as claimed. Further, the assessee has not provided the details of the cost incurred for various services rendered by its AE, the basis of allocation of the cost to the assessee. It has not demonstrated that the services rendered (on a without prejudice basis) has any value. It has not provided any comparable instance to demonstrate the ALP of these transactions. On the facts of this case the assessee has not been able to establish the identification of the cost incurred by the group entity in providing services to the assessee. In the facts of instant case, the assessee has not been able to adequately substantiate that services have been rendered by the AE or that the assessee has availed any service from the AE. In this case the assessee company has failed to prove evidence in respect of the followings,- a) The benefits received by the Assessee VE TAX b) When and how such services were rendered by the AE and c) At what rate these services were available in the open market. 18.2 Without the any....
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....7. The Assessing Officer is directed to go through the Paragraphs above and succinctly assess the income accordingly. Needless to mention, there would not be double addition / disallowance of Rs. 5,52,62,002/-, but the Assessing Officer will provide the additional supporting argument that the sums have not only "Nil" ALP as determined by the Ld. TPO; but also are not eligible for deduction under s.s. 37(1) of the I.T. Act. This is an additional ground raised by the Panel. The Assessing Officer is directed to comply with the additional ground and incorporate the same. 1.5. Direction of the DRP: The Assessing Officer is directed to make disallowance of Rs. 5,52,62,002/- claimed as Management Consultancy Services payment to AEs on account of lacking in establishment of "receipt" of services, absence of business nexus and no case of service rendition. The claim of deduction does not pass the factual/legal tests of sub-section 37(1). This is to be taken as a supporting and alternate ground to Ld. TPO's action of setting the ALP of the claims services at "Nil". It is directed that the Assessing Officer is to discuss the above ground in assessment o....
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.... including (a) the nature of the transaction, (b) the functions, assets and risks of the AEs, (c) availability and reliability of data, (d) degree of comparability, (e) reliability of adjustments to account for differences, and (f) nature and reliability of assumptions required. 10.3 It was submitted that after considering the above parameters, the assessee selected the "Other Method" as the MAM for benchmarking the service fee for intra-group services. According to the Ld. AR, the TPSR demonstrates that the assessee followed a methodical and regulation-compliant approach in determining the ALP. 10.4 The Ld.AR emphasized that the statutory framework for determination of ALP is equally binding on the Revenue authorities. In the present case, the Ld.TPO has not identified a single comparable uncontrolled transaction nor has he applied any of the prescribed methods under Rule 10B. It was argued that a determination of ALP at Nil, without application of any recognised method or any comparable data, is contrary to the statutory scheme and therefore unsustainable in law. 10.5 The Ld.AR submitted that determination of ALP for service transactions necessarily requires identificati....
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....at were closely linked to the assessee's marketing data analytical services and other operational activities. The assessee's decision to apply a corroborative TNMM analysis by aggregating these transactions and comparing its net cost-plus margin with that of independent broadly comparable companies is fully in consonance with the principle of aggregation recognised in para 1.42. 11.2 Notably, the Ld. TPO did not undertake any functional or factual analysis to establish that the transactions were capable of being benchmarked independently or that aggregation would distort the arm's-length outcome. In the absence of such examination, the outright rejection of the assessee's approach is unjustified. 11.3 Further, para 7.36 of the OECD Guidelines emphasises that the essential test for intra-group services is, whether the services confer an economic or commercial benefit such that an independent enterprise would have been willing to pay for them. The assessee placed substantial contemporaneous evidence running from pages 138-368 and supplemented by further documents at pages 369-466 of the Paper Book, demonstrating the nature of services received, their relevance t....
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....applying the principles contained in OECD paras 1.42 and 7.36, as well as the statutory mandate under Sections 92C and 92CA read with Rules 10B and 10C, we are satisfied that the assessee has carried out a methodological sound and reliable benchmarking analysis for the international transaction relating to payment of management consultancy services. The assessee has demonstrated the integrated nature of the services, the commercial benefits derived, and the appropriateness of the 5% and 10% mark-ups in accordance with its global policy. The corroborative TNMM results further fall within the arm's-length range. 11.8 In light of the detailed discussion above, and having regard to the statutory mandate under sections 92C and 92CA read with Rules 10B and 10C, as well as the OECD principles contained in paras 1.42 and 7.36, we consider it appropriate to issue the following operative directions to the Assessing Officer/TPO. 11.9 The Ld.AO/TPO shall accept the assessee's benchmarking framework for the international transaction relating to payment of management consultancy services, including: 1. The adoption of the "Other Method" as the preferred and primary method ....
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.... this stage. Considering the submission of the assessee the legal issue raised by the assessee in Additional Ground no. 11 is kept open to be contested in appropriate circumstances. 14. Additional Ground No. 12-13 We have considered the rival contention of both sides on the issue. It is submitted that any AE related transaction cannot be interfered with by the Ld.AO once the transaction is referred to determine the ALP under the provisions of section 92CA of the Act. It is submitted that, the DRP has directed alternate disallowance once the Ld.TPO to be made without granting any opportunity of being heard to the assessee It is verifiable from the record that no such addition was proposed in the draft assessment order. The DRP has passed direction to make alternative addition without issuing any notice. In any event based on our observation and reasoning while adjudicating grounds 5 to 10 this disallowance cannot be made. Therefore no further adjustment under the general deduction provisions shall survive in the present facts of the case. Accordingly the Additional grounds 12-13 raised by the assessee stands allowed. In the result the appeal filed by the assessee s....
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....elhi High Court have been reproduced hereunder for ready reference. Para 31 5. "As explained. for 82.44% share of the revenue from the services of the Client Solution Group, the relatable cost allocation was 72.5%. The precise activities conducted by the Client Solutions Group for the benefit of the assessee out of the entire range of activities Document 2 conducted by it, and the cost applicable to such activities have not been provided. Instens a broad-brush approach at flatly 'equating' the costs relatable to the revenue generated has been provided. Whilst several e-mails from Mr. Arshpreet Choudhary were placed on record, they evidence the fact that certain services were rendered. That constitutes only the first part of the exercise - the second aspect is to relate the cost of specific activities conducted to the benefit incurred by the assessee, rather than allocate cost from a common pool or basket of revenue generated through an unexplained percentage relation to the revenue generated. The basis for the costs incurred, the activities for which they were incurred, and the benefit accruing to the assessee from those activities must all be proved to determine first, w....
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....oup. It is essential, however, that reliable documentation is provided to the tax administrations to verify that the costs have been incurred by the service provider" 9. The attention is invited to assessce's own Master Services Agreement and Para 4 of the same is reproduced below- "4 Supporting Documentation- The Service Provider shall make support related to the underlying Fees payable available to the Service Recipient on request. The Service Recipient shall have the right to inspect, during normal business hours and upon reasonable advance notice, such books, records Document 3 and other supporting data of the Service Provider' service centre as may be reasonably necessary to verify the Service Providers' computation of the Fees." 10. Further the para 2 in Section 2 of the agreement (assessee'spaperbook page 112) clearly mentions that the fee for the services will be determined as an arm's length mark-up on costs incurred in rendering of these services. The service provider is supposed to calculate the aggregate of all costs incurred by the service provider in rendering the services covered by the agreement. This clearly indicates that not only did the assessee ....
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....lling to pay for it. Further the guidelines specifically exclude circumstances like duplication, incidental benefits, shareholder activities etc. Thus, as a first step in analysis the Transfer Pricing Analysis of IGS, it is essential for AO to determine whether services have been rendered or not. 17. In this respect the attention is invited to Rule 10D(1), clause (d) and the same is reproduced below- "Information and documents to be kept and maintained under section 92D. Document 4 10D. (1) Every person who has entered into an international transaction or a specified domestic transaction shall keep and maintain the following information and documents, namely: (a) ... (d) the nature and terms (including prices) of international transactions or specified domestic transactions entered into with each associated enterprise, details of property transferred or services provided and the quantum and the value of each such transaction or class of such transaction" 18. Thus, it is apparent that the details of quantum and value (or quantity and quality) are to be provided and not just copies of vague communications between the employees of the assessee. In this respect the atte....
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....such effort was made. No ALP was computed by the assessee." 20. Thus, the evidenceshave to be of such nature that they prove the quantum and value and the benefit test is to be applied on these parameters. The reference is also made to the case of Crane Software International Lt in IT(TP)A No. 1594/Bang/2012, where Hon'ble Bangalore Bench held that absent proof of service, the agreements between affiliates "could be best considered only as self-effectuating documents" and that the AL.P in such cases would be "zero". The relevant part from para 9 is reproduced below: Document 5 "When assesseeis not able to bring on record anything to show any services to have been rendered by AE to it and there are no documentations to show any services to have been received from AE, in our opinion it will be fair conclusion that no services were in fact rendered the by AEs to the assessie. There is no dispute that both the AEs were subsidiaries of the assessee. Therefore, the agreements between such subsidiaries, which have been brought before us as well as lower authorities for justifying the payments could be best considered only as self-effectuating documents. There was considerable onus ....
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....arly mentions that the fee for the services will be determined as an arm's length mark-up on costs incurred in rendering of these services. The service provider is supposed to calculate the aggregate of all costs incurred by the service provider in rendering the services covered by the agreement. This clearly indicates that the assessee had access to Document 6 22.4. It is also important to note here that the Fees payable by the Service Recipient has in fact been calculated based on recipient's share of total net sales achieved relative to worldwide net sales. In this respect it may be noted that since different geographic or economic regions are likely to earn different margins on the same kind of services, such a distribution of service provider's costs would misallocate higher costs to regions likely to earn a higher margin on the given services (e.g. India as opposed to USA or Europe). Thus, the allocation of cost on the basis ofassessce'snet sales as a part of worldwide net sales would not only entail a verification of the total cost incurred by the AE and total sales of the group, itis not a proper or arm's length allocation of costs also. 22.5. Submission before TPO d....
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....ly was involved as an open-ended question. These descriptions instead of clearly describing the activities performed in context of the transaction under examination would typically refer to these activitiesas "resource co-ordination". "global strategy". "maximum customer satisfaction", i.e. the descriptions under which almost anything can be claimed. Almost no facts in respect of what exactly were the activities under the impugned transactions towards which the payments have been made to AE, are disclosed. Thus, the assessce failed to bring out even the claims of facts clearly and the claims in written submissions made before AO were extremely general, non- specific and open ended. Document 7 22.6.4. The page numbers from 181 to 194 is another copy of 'Master Services Agreement". the actual documents appear to be starting from page 195. In the written submission vide which these documents were submitted before TPO, the same have been referred to as different Exhibits to the submission. The findings of these exhibits and their page numbers in PB of current appeal are as follows. 22.6.5. Pages 195 to 198 is "Exhibit 2", which starts with a list of "Useful Links"has a descripti....
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....hase and total login hours of the assessce as in comparison to group's aggregate login hours would have proven the receipt. Instead, a single screen shot of the login page has been submitted, with no description of who bought it, who paid for it and what was role of assessee and AE has been brought out. 22.6.11. Page 223-225 of current appeal paperbook, described as Exhibit 10 in submissions before, has been claimed to be Group's 'Global IT Policy". Of course, an MNE groupwould have an IT Policy to protect its own data and prevent data leak law suits in their own jurisdictions. This is clear from page 223 of the paperbook wherein it has been mentioned that the thisIT policy is a as result of Kantar's contractual obligations. In other words, because the AE has to protect the data of its own clients it casts restrictions on use of its own data, puts burden of security on users, casts obligations for secure storage of information, prohibits sharing of data etc. In light of the fact that the assessee is also providing services to Al and hence regularly accessing the data of AE's clients these guidelines are for protection of AE only and Document 8 not assessee. Further even t....
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....receives them and who provides them, proves nothing to support assessce's case.In any case there is no evidence that any of the employees of the assessce received any trainings at all and the role of AE in the same. 22.6.13. Pages 348 to 358 of current appeal paperbook, are directions issued to follow local Covid Related directions, asking to be generally careful in making disbursals and putting restrictions on some payments. In no way these general recommendations, which were available on health department websites and freely on websites of many corporates can be considered as services. 22.6.14. Pages 359 to 364 of current appeal paperbook and described as Exhibit 16-17 in submissions made before TPO have been claimed as 'stop payment policy toolkit" and "copy of business travel insurance provided by the group to all employees. On perusal of these documents it was noted that these are details of policies in place for WPP employees (and not assessce group's employees and it is not known as to how is WPP group related to the assessee group). If any of these policies have been bought by the AE for the employees of the assessee then a simple list of employees covered and p....
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.... that the assessee will certainly have multiple communications between different AEs of the group and the MNE would try to control the assessee to protect their own interests and to that extent multiple activities and communications would certainly be there. However, not all these activities would be chargeable services and the standard test to decide the same is determination of whether a third party would be willing to pay for such activities. The satisfaction of the need, benefit and rendition test is one such way to ascertain whether any chargeability at all is there or not. Once it is ascertained that a third party will not be willing to pay or that need, benefit and rendition tests have not been satisfied, the bench-marking process is over, and the AL.P has been arrived at as 'Nil'. Once it has been ascertained that 3rd parties will not pay it would be a futile exercise to look for comparable data because no such data would be disclosed by companies. It would be pointless to look for specific methods and do a calculation of AL.P because AL.P has already been arrived at as 'nil'. In this respect the attention is invited to the judgment of Hon'ble Mumbai Bench in case of Lintas....
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....s not benefit the recipient of services. In view of this, it is required to be examined whether the assessee has fulfilled the above criteria or not. It is always necessary to maintain a full-proof document of every business activity, however, if the document is not available ofparticular business activity, there is nothing wrong as whole world will presume that it is not done. If that be the case, the determination of arm's-length price at Rs. nil is proper." 27. The four "specific tests" referenced in Lintas-proof of request, rendition, benefit and market comparability are essential and consequently, adopting the CUP method and fixing a NII. price is not merely permissible; it is mandated by the only tribunal authority directly on point. The OECD Transfer-Pricing Guidelines (2022) reinforce the conclusion. Paragraph 7.6 states: "Under the arm's length principle, the question whether an intra-group service has been rendered ... should depend on whether the activity provides a respective group member with economic or commercial value to enhance or maintain its business position. ... If the activity is not one for which the independent enterprise would have been willing to pay....
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....SC), that an additional ground can only be allowed if assessee if assessee proves that there were good reasons for failure to raise these grounds before lower authorities and the complete facts to decide the ground are there on record. Since no such case has been made, it is humbly urged that the ground may not be allowed. 32. In this respect it is pointed out that the only transaction that has been examined by TPO in his order is the receipt of impugned services from the AE. The entity level benchmarking under TNMM has not been examined and hence it cannot be concluded that TPO has accepted the entity level benchmarking. Improper entity level benchmarking 33. In this respect it is further pointed out that the entity level benchmarking of the assessee. as per their TP Document has been done for IT enabled Services and selected the following service groups (PB Pages 60 and 61)- · Communication Services- Included 'Internet Services' and 'Other Communication Services' . Business Services- Included Other Consultancy Services, Event Management Services, Database Services, Business Brokerage Services, Renting Services . Information Technology- included Software Servi....