McKinsey Global Capabilities & Service P. Ltd. vs. Additional/Joint/Deputy/Assistant Commissioner of Income Tax
Case No: ITA No. 984/Del/2021(A.Y 2016-17)
Court: Income Tax Appellate Tribunal, Delhi Bench ‘I’
Date: 4/21/2026
Parties Involved
appellantMcKinsey Global Capabilities & Service P. Ltd.
respondentAdditional/Joint/Deputy/Assistant Commissioner of Income Tax
Facts Summary
The assessee, McKinsey Global Capabilities & Service P. Ltd., is a subsidiary of McKinsey Holding Inc., USA, engaged in providing research, information, and IT support services to its Associated Enterprises (AEs). For the assessment year 2016-17, the assessee declared an income of INR 70,82,05,260/-. The assessee entered into various international transactions, including the provision and availing of support services and reimbursement of expenses. A Transfer Pricing Officer (TPO) was referred to…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the AO erred in making a transfer pricing adjustment of INR 6,16,85,832 to the total income of the Appellant in respect of international transactions.
- 2. Whether the AO erred in making reference to an incorrect order while incorporating the transfer pricing adjustment.
7 more legal issues analysed in this judgement.
Precedents Relied Upon
2 precedents cited in this judgement.