Services had been actually rendered by AE to it, lower authorities were justified in considering ALP to be nil

IT/ILT: Where assessee had not been able to bring anything on record to prove that services had been actually rendered by AE to it, lower authorities were justified in considering ALP to be nil
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[2014] 52 taxmann.com 19 (Bangalore - Trib.)
IN THE ITAT BANGALORE BENCH 'C'
Cranes Software International Ltd.
v.
Deputy Commissioner of Income-tax, Circle- 11 (2), Bangalore*
RAJPAL YADAV, JUDICIAL MEMBER
AND ABRAHAM P. GEORGE, ACCOUNTANT MEMBER
IT (TP) APPEAL NO. 1594 (BANG.) OF 2012
[ASSESSMENT YEAR 2008-09]
SEPTEMBER  26, 2014
Section 92C of the Income-tax Act, 1961 read with rule 10D of the Income-tax Rules, 1962 - Transfer pricing - Computation of arm's length price (Comparables & Adjustments) - Assessment year 2008-09 - Whether when assessee was not able to bring on record anything to show any services to have been rendered by AE to it and there were no documentations to show any services to have been received from AE, it was rightly concluded that no services were in fact rendered by AEs to assessee - Held, yes - Whether since no services were received by assessee from its AEs, lower authorities were justified in considering ALP to be nil - Held, yes [Para 9][In favour of revenue]