McKinsey & Company India LLP Vs Additional / Joint / Deputy/Assistant Commissioner of Income Tax, Income-tax Officer, National e-Assessment Centre, Delhi-110002.
Parties Involved
Facts Summary
The assessee, McKinsey & Company India LLP, filed an appeal against the final assessment order dated 30.06.2021 passed under section 143(3) read with section 144C(3) r.w.s. 144B of the Income-tax Act, 1961. The appeal was filed pursuant to the directions of the Hon'ble Dispute Resolution Panel (DRP) order dated 30.09.2020 for Assessment Year 2016-17. The assessee filed a written request seeking withdrawal of the appeal due to the resolution of disputes under the Mutual Agreement Procedure (MAP) contained in Article 27 of the India–USA Double Taxation Avoidance Agreement. The assessee accepted the MAP resolution and sought to withdraw all grounds of appeal.…
Decision in favour of
Revenue
Legal Issues
- 1. Transfer pricing adjustments under the Mutual Agreement Procedure (MAP).
Judgment Outcome
Decided in favour of Revenue.
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