AXA Alert

The Tribunal bore on the reliance placed by the taxpayer on its Advance Pricing Agreement arrangement with Revenue Authorities for the disputed transaction, and thereby disdained the TPO's determination of ALP for payment of management fees at 'Nil' on ground of absence of concrete evidences

Facts of the Case

AXA Technologies Shared Services Pvt. Ltd. ["the taxpayer"] is engaged in the business of providing IT Infrastructure services to AXA group operating companies.  During the assessment year under review, the taxpayer entered into an international transaction with its associated enterprise ["AE"] for rendering Information technologies enabled services ["ITES"] and payment of management fees.  For benchmarking aforesaid transactions, the taxpayer applied Transactional Net Margin Method ("TNMM") on entity wide basis.