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Bg Exploration & Production India Ltd., ... vs Jcit, Dehradun on 24 April, 2017

14. So, in view of the matter, we are of the considered view that when the entire evidence has been brought on record or assessed during TP proceedings as has been discussed in the preceding paras to prove the fact that adjustment of RS.4,85,779/- on account of time writing charges is at arm's length and also in consonance with the order passed by ld. DRP in AYs 2009-10 and 2010-11 in BG Exploration & Production India Ltd. decided by the coordinate Bench of the Tribunal vide order dated 28.04.2017 (supra) to whom similar services have been rendered by BGIL, the ld. TPO is directed to examine the issue afresh for determination of the ALP of the time writing charges paid by the assessee in the light of the decision rendered by the coordinate Bench of the Tribunal in BG Exploration & Production India Ltd. (supra) by following the rule of consistency.
Income Tax Appellate Tribunal - Delhi Cites 66 - Cited by 34 - Full Document
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