Dismissing the appeal of the revenue the Tribunal held that the payment to intra-group services and not steward activity hence the ALP determination was not adjudicated since no ground has been raised by the revenue. (AY. 2009-10)
ACIT v. Nalco Water India Ltd (2021) 208 DTR 85/ 133 taxmann.com 531 /(2022) 215 TTJ 551 (Pune)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Payment to intra-group services and not stewardship activity-ALP determination was not adjudicated-No ground was raised by the revenue.