The Income Tax Appellate Tribunal ( ITAT ), Mumbai bench directed a readjudication with respect to the denial to grant Tax Deduction at Source ( TDS ).
The Assessee, Crisil Limited, has two business divisions, namely (i) Ratings and (ii) Research. Under the Ratings segment, the Assessee is engaged in rendering back-end support for data analysis services to its associated enterprises through the Global Analytical Centre ( GAC ), which is the transaction under dispute. During the assessment proceedings, the AO refused to grant Tax Deduction at Source.
Aggrieved by the order, the assessee filed an appeal before the Dispute Resolution Panel. The DRP dismissed the appeal filed by the assessee. Thereafter, the assessee filed an appeal before the tribunal.
After analyzing the submissions of both parties, the bench comprising Aby T Varkey ( Judicial Member ) and S. Rifaur Rahman ( Accountant Member ) remitted this issue back to the file of the Assessing Officer with a direction to verify the records submitted by the assessee on merit and as per law.
Dhanesh Bafna, the counsel appearing for the assessee, and Vachashpati Tripathi, counsel appearing for the Department representatives, were present during the proceedings.
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