That the Revenue was unable to controvert the fact that none of the expenses made by the assessee on behalf of the associated enterprises involved rendering of services by the assessee but were merely meeting of expenses of statutory duties dues, fees or charges of the associated enterprises. Neither did the Revenue dispute the fact that all the expenses were made out of advances given by the associated enterprises to the assessee. Order of CIT(A) is affirmed. (AY.2011-12)
Dy. CIT v. Aatash Narcontrol Ltd. (2023)103 ITR 334/ 149 taxmann.com 157 (Ahd)(Trib)
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Reimbursement of expenses on actual-cost basis-Meeting of statutory duties, fees and other charges-Adjustment is not valid. [S.92CA]