The Tribunal remanded the matter to the AO to decide the issue afresh of allocation of non-syndication fees between the assessee and its associated enterprise. On appeal High Court held that, on the facts there was no error or infirmity in the view taken by the Tribunal in remanding the matter to the AO. for a fresh decision. (AY. 2008-09)
CIT v. RBS Financial Services (India) Pvt. Ltd. (2020) 421 ITR 1 (Bom.)(HC )
S. 92C : Transfer pricing-Arm’s length price-Loan syndication fee received from associated enterprise-Tribunal remitting matter to AO-Not erroneous.[S. 254(1), 260A]