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2. As per the petitioner, it is engaged in the business of providing corporate and management services, in terms of the agreement with its Associate Enterprise (AE) i.e. AECOM India Private Limited. The petitioner provides management and governance support functions in the area of legal, tax, treasury, finance, information technology, human resources, enterprise risk management, etc.

8. On going through the entire order, we find that the Competent Authority has neither disputed the nature of the transaction nor has he recorded any finding about the taxability of the transaction, which the petitioner has undertaken with its AE-AECOM India Private Limited. Even petitioner's assertion/contention that his earlier writ petition was allowed by this Court and direction was issued to grant certificate at nil rate has been side tracked on flimsy ground that the Department has decided to file an SLP against such order.