It additionally held that the sooner MAP decision was not binding on evaluation years it didn’t expressly cowl. Its profit may very well be prolonged to subsequent years provided that there was no change within the info or capabilities carried out by the everlasting institution.
Nonetheless, the ITAT discovered the 15 % attribution extreme.
“It’s equally true that the AO on mere estimation has enhanced the attribution of revenue from 8.75% to fifteen%. In our thought of view the speed of attribution as decided by the AO could be very a lot on increased facet,” it noticed.
The tribunal, subsequently, restricted the attribution to 12 %.
